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 - Reasons which were supplied to the petitioner were not the actual reasons and the objections which were taken by the petitioner were not to the actual reasons - The entire process would be a sham and would amount to making a mockery of the law. Therefore, for this reason also, the notice under section 148 as well as all proceedings subsequent thereto as also the order are liable to be quashed.
Reopening of assessment u/s 147 - Reasons which were supplied to the petitioner were not the actual reasons and the objections which were taken by the petitioner were not to the actual reasons - The entire process would be a sham and would amount to making a mockery of the law. Therefore, for this reason also, the notice under section 148 as well as all proceedings subsequent thereto as also the order are liable to be quashed.
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