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...
Faceless assessment - return was processed under Section 143(1) - As incumbent upon the respondent/revenue to accord a personal hearing to the petitioner. - The entire scheme, encapsulated under Section 144B of the Act, was laid down to bring transparency as well as accountability in the system.According to us, irrespective of whether such a statutory scheme was framed or not, the system has to be both, transparent, and the persons administering it, have to remain accountable. - HC
Faceless assessment - return was processed under Section 143(1) - As incumbent upon the respondent/revenue to accord a personal hearing to the petitioner. - The entire scheme, encapsulated under Section 144B of the Act, was laid down to bring transparency as well as accountability in the system.According to us, irrespective of whether such a statutory scheme was framed or not, the system has to be both, transparent, and the persons administering it, have to remain accountable. - HC
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