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 re opening of the assessment - ITAT held that CIT(A) fell in error in holding the re-assessment to be invalid - it is evident that the order passed by the tribunal has been passed in a cryptic and cavalier manner and well reasoned order passed by the Commissioner of Income Tax (Appeals) has been set aside without assigning any cogent reasons. - Matter restored before ITAT - HC
Validity of re opening of the assessment - ITAT held that CIT(A) fell in error in holding the re-assessment to be invalid - it is evident that the order passed by the tribunal has been passed in a cryptic and cavalier manner and well reasoned order passed by the Commissioner of Income Tax (Appeals) has been set aside without assigning any cogent reasons. - Matter restored before ITAT - HC
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