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...
A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the annual return due date has been reached; each financial year must be adjudicated separately. Applying an earlier Division Bench view, the HC set aside the impugned Order in Original because it covered four financial years in one order. The matter was remitted for fresh proceedings year-wise, with liberty to initiate separate proceedings for each assessment year, and the intervening period was directed to be excluded for limitation. All other grounds of challenge were left open.
A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the annual return due date has been reached; each financial year must be adjudicated separately. Applying an earlier Division Bench view, the HC set aside the impugned Order in Original because it covered four financial years in one order. The matter was remitted for fresh proceedings year-wise, with liberty to initiate separate proceedings for each assessment year, and the intervening period was directed to be excluded for limitation. All other grounds of challenge were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
