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...
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
