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 notice u/s 148 - “reason to believe" must be interpreted that the AO on receipt of any such new material or materials in relation to the non furnishing of fact by the assessee has made out a prima facie opinion that it is the case for reopening of the assessment - in the absence of having knowledge about the reasons, the petitioners cannot come to the conclusion that there is no new material or reason to reopen the assessment - writ dismissed
Reassessment notice u/s 148 - “reason to believe" must be interpreted that the AO on receipt of any such new material or materials in relation to the non furnishing of fact by the assessee has made out a prima facie opinion that it is the case for reopening of the assessment - in the absence of having knowledge about the reasons, the petitioners cannot come to the conclusion that there is no new material or reason to reopen the assessment - writ dismissed
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