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...
Jurisdiction - validity of registration with wrong PAN no.- The cancellation was with effect from 30th November 2019 and not from 29.9.2018. For all these period, there were no returns, which necessitated the assessing officer to assume the role of best assessment u/s 62 - Thus for all intends and purposes, there cannot be any bonafide omission or mistake.
Jurisdiction - validity of registration with wrong PAN no.- The cancellation was with effect from 30th November 2019 and not from 29.9.2018. For all these period, there were no returns, which necessitated the assessing officer to assume the role of best assessment u/s 62 - Thus for all intends and purposes, there cannot be any bonafide omission or mistake.
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