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 order - faceless assessment - Violation of provisions of Section 144B - That being the position, there is no option, but to set aside the impugned assessment order dated 15.04.2021, issued under Section 143(3), read with Sections 143(3A) and 143(3B) of the Act, along with accompanying notice of demand, issued under Section 156 of the Act and notice for initiation of penalty proceedings, issued under Section 270A of the Act. - HC
Validity of assessment order - faceless assessment - Violation of provisions of Section 144B - That being the position, there is no option, but to set aside the impugned assessment order dated 15.04.2021, issued under Section 143(3), read with Sections 143(3A) and 143(3B) of the Act, along with accompanying notice of demand, issued under Section 156 of the Act and notice for initiation of penalty proceedings, issued under Section 270A of the Act. - HC
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