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...
Site restoration expenditure was held deductible, as the Court noted that the connected appeals had already upheld the assessee's claim under Section 37(1); once that position was accepted, the Revenue's challenge to the Tribunal's view on book profit treatment also failed. The reassessment for AY 1999-2000 was also sustained as invalid: it had been initiated after four years, the assessee was not supplied the recorded reasons, no notice under Section 143(2) was served, and the Department failed to justify reopening beyond limitation before the appellate authorities.
Site restoration expenditure was held deductible, as the Court noted that the connected appeals had already upheld the assessee's claim under Section 37(1); once that position was accepted, the Revenue's challenge to the Tribunal's view on book profit treatment also failed. The reassessment for AY 1999-2000 was also sustained as invalid: it had been initiated after four years, the assessee was not supplied the recorded reasons, no notice under Section 143(2) was served, and the Department failed to justify reopening beyond limitation before the appellate authorities.
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