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...
Reassessment notices must be initiated through the faceless assessment framework rather than by the Jurisdictional Assessing Officer where algorithm-based random allocation governs reassessment proceedings. A final assessment order issued under the faceless regime does not cure the initial jurisdictional defect. Where the final order is already challenged before the Commissioner of Income Tax (Appeals), the jurisdictional objection should be raised and considered in that statutory appeal, applying the relevant High Court precedents. The assessment order need not be independently quashed in writ proceedings when the pending appeal can address the objection.
Reassessment notices must be initiated through the faceless assessment framework rather than by the Jurisdictional Assessing Officer where algorithm-based random allocation governs reassessment proceedings. A final assessment order issued under the faceless regime does not cure the initial jurisdictional defect. Where the final order is already challenged before the Commissioner of Income Tax (Appeals), the jurisdictional objection should be raised and considered in that statutory appeal, applying the relevant High Court precedents. The assessment order need not be independently quashed in writ proceedings when the pending appeal can address the objection.
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