Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Non-compliance with a remand direction requiring completion of penalty proceedings within 12 weeks rendered the reinitiated proceedings unsustainable. The record showed that no final order under the penalty provision had been passed within the stipulated period and no extension of time had been sought. Mere issuance of show-cause notices did not amount to compliance, especially where repeated requests for a hearing had not been effectively addressed. On that ground, the show-cause notices issued in continuation of the remand were quashed.
Non-compliance with a remand direction requiring completion of penalty proceedings within 12 weeks rendered the reinitiated proceedings unsustainable. The record showed that no final order under the penalty provision had been passed within the stipulated period and no extension of time had been sought. Mere issuance of show-cause notices did not amount to compliance, especially where repeated requests for a hearing had not been effectively addressed. On that ground, the show-cause notices issued in continuation of the remand were quashed.
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