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...
Income-tax Officer (Intelligence) authority to issue notice u/s 133(6) - Jurisdiction of Income Tax Authorities u/s 120 - From the reliance on the notification dated November 1, 2011, it is decipherable that the power of collection, collation and dissemination which earlier vested with Central Information Branch was transferred to Income-tax Officer (Intelligence), which would not mean that the notices issued and imposition of penalty by the Income-tax Officer (Intelligence) lacked jurisdiction. - HC
Income-tax Officer (Intelligence) authority to issue notice u/s 133(6) - Jurisdiction of Income Tax Authorities u/s 120 - From the reliance on the notification dated November 1, 2011, it is decipherable that the power of collection, collation and dissemination which earlier vested with Central Information Branch was transferred to Income-tax Officer (Intelligence), which would not mean that the notices issued and imposition of penalty by the Income-tax Officer (Intelligence) lacked jurisdiction. - HC
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