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...
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
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