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...
Payment of the demanded tax, penalty and fine in GST detention and confiscation proceedings did not dispense with the proper officer's duty to adjudicate the show cause notice by a formal, reasoned order. The Court held that consideration of the taxpayer's reply and issuance of a speaking order are part of natural justice and necessary to preserve the statutory appellate remedy. Because the release order did not amount to final adjudication and no reasoned order had been passed, the penalty order could not stand and was set aside. Liberty was granted to pass a fresh speaking order after personal hearing and complete the statutory summary.
Payment of the demanded tax, penalty and fine in GST detention and confiscation proceedings did not dispense with the proper officer's duty to adjudicate the show cause notice by a formal, reasoned order. The Court held that consideration of the taxpayer's reply and issuance of a speaking order are part of natural justice and necessary to preserve the statutory appellate remedy. Because the release order did not amount to final adjudication and no reasoned order had been passed, the penalty order could not stand and was set aside. Liberty was granted to pass a fresh speaking order after personal hearing and complete the statutory summary.
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