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 assessment - show cause notice has been issued manually - The petitioner refers to a snap shot of the E-portal contending that does not refer to show cause notice dated 20.05.2019. This would, at best, amount to a technical error and will not vitiate the assessment itself for the reason that the show cause notice has been manually issued and proof of service of the same is also available on record. - The challenge to the assessment thus fails - HC
Validity of assessment - show cause notice has been issued manually - The petitioner refers to a snap shot of the E-portal contending that does not refer to show cause notice dated 20.05.2019. This would, at best, amount to a technical error and will not vitiate the assessment itself for the reason that the show cause notice has been manually issued and proof of service of the same is also available on record. - The challenge to the assessment thus fails - HC
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