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...
Validity of reopening of assessment - notice under section 148 issued at wrong address - While passing impugned reassessment order, principle of natural justice and ‘audi alterm partem’ needs to be followed. - impugned notice issued u/s148 at the wrong address quashed and the consequential assessment order passed is set aside. - AT
Validity of reopening of assessment - notice under section 148 issued at wrong address - While passing impugned reassessment order, principle of natural justice and ‘audi alterm partem’ needs to be followed. - impugned notice issued u/s148 at the wrong address quashed and the consequential assessment order passed is set aside. - AT
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