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 - High Court dismissed writ against notice u/s 148 - the proper remedy of the petitioner would be to raise all pleas before the AO in assessment proceedings and if it is decided against him then to carry appeal to CIT (A) and then to the Tribunal and then to the High Court u/s 260A - not inclined to interfere with impugned order passed by the High Court
Reopening of assessment - High Court dismissed writ against notice u/s 148 - the proper remedy of the petitioner would be to raise all pleas before the AO in assessment proceedings and if it is decided against him then to carry appeal to CIT (A) and then to the Tribunal and then to the High Court u/s 260A - not inclined to interfere with impugned order passed by the High Court
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