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...
Proceedings under Section 148A cannot be initiated against a deceased assessee; where the assessee has died, the Department must invoke the statutory mechanism under Section 159 against the legal representatives. As that route was not followed here, the notices were unsustainable and were quashed, while liberty was preserved for the Department to proceed in accordance with law against the legal representatives.
Proceedings under Section 148A cannot be initiated against a deceased assessee; where the assessee has died, the Department must invoke the statutory mechanism under Section 159 against the legal representatives. As that route was not followed here, the notices were unsustainable and were quashed, while liberty was preserved for the Department to proceed in accordance with law against the legal representatives.
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