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 u/s 147 - within 4 years from the end of relevant AY - when no opinion was formed by Ld. AO on any issue during original assessment proceedings and the same was altogether skipped, there would be no bar to reach the requisite satisfaction on the basis of findings in subsequent assessment year - In such a case, deeming fiction of Explanation-2 would come into play and the income shall be deemed to have escaped assessment
Reassessment u/s 147 - within 4 years from the end of relevant AY - when no opinion was formed by Ld. AO on any issue during original assessment proceedings and the same was altogether skipped, there would be no bar to reach the requisite satisfaction on the basis of findings in subsequent assessment year - In such a case, deeming fiction of Explanation-2 would come into play and the income shall be deemed to have escaped assessment
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
