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...
Period of limitation to pass assessment order in case of remand proceedings u/s 153 - An order of any Court means an order of any and every Court of the country. - The hierarchy in status of the Court in the country is not decisive. As provided in Section 153(6) of the Act, that there must be a Court, and there must be an order of the Court. Therefore, when this Court remands the matter, it is an order of the Court which would extend the limitation for completing the assessment by the Assessing Officer for another twelve months. - HC
Period of limitation to pass assessment order in case of remand proceedings u/s 153 - An order of any Court means an order of any and every Court of the country. - The hierarchy in status of the Court in the country is not decisive. As provided in Section 153(6) of the Act, that there must be a Court, and there must be an order of the Court. Therefore, when this Court remands the matter, it is an order of the Court which would extend the limitation for completing the assessment by the Assessing Officer for another twelve months. - HC
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