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 u/s 153C - Reopening of assessment u/s 147 - In view of such glaring fact covering huge racket of providing accommodation entries of issuing bogus bills, the ld. CIT (Appeals) being conscious of his powers and his authority in directing the ld. Assessing Officer to issue notice under Section 147/148 - CIT-A in guiding the AO giving a direction to proceed u/s 147-148 of the act are in conformity with the income tax act, the direction itself does not prohibit or curtail upon any power of the assessing officer mentioned in those sections, it is in conformity with the provisions of the law and by merely giving this directions the assessee is not aggrieved at all as he has all the rights vested in the income tax act to challenge such action of the assessing officer as and when taken. - AT
Validity of Assessment u/s 153C - Reopening of assessment u/s 147 - In view of such glaring fact covering huge racket of providing accommodation entries of issuing bogus bills, the ld. CIT (Appeals) being conscious of his powers and his authority in directing the ld. Assessing Officer to issue notice under Section 147/148 - CIT-A in guiding the AO giving a direction to proceed u/s 147-148 of the act are in conformity with the income tax act, the direction itself does not prohibit or curtail upon any power of the assessing officer mentioned in those sections, it is in conformity with the provisions of the law and by merely giving this directions the assessee is not aggrieved at all as he has all the rights vested in the income tax act to challenge such action of the assessing officer as and when taken. - AT
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