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...
Reopening of assessment u/s 147 - AO has re-appreciated trial balance-sheet which is also available to him when original assessment order was passed and alleged escapement - proviso appended to section 147 puts an embargo in the exercise of power of AO in cases where scrutiny assessment has taken place and four years have expired from the end of relevant AY if assessee has disclosed all material facts fully and truly - reassessment quashed
Reopening of assessment u/s 147 - AO has re-appreciated trial balance-sheet which is also available to him when original assessment order was passed and alleged escapement - proviso appended to section 147 puts an embargo in the exercise of power of AO in cases where scrutiny assessment has taken place and four years have expired from the end of relevant AY if assessee has disclosed all material facts fully and truly - reassessment quashed
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
