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...
Reopening of assessment u/s 147 - bogus transactions or accommodation entries involving the assessee - the petitioner was issued a notice under section 133(6) of the said Act requesting it to furnish the evidence to prove the genuineness of the transactions mentioned therein before the issuance of the impugned notice u/s 148 of the said Act, however, the petitioner had chosen not to respond to the said notice. - Reopening sustained - HC
Reopening of assessment u/s 147 - bogus transactions or accommodation entries involving the assessee - the petitioner was issued a notice under section 133(6) of the said Act requesting it to furnish the evidence to prove the genuineness of the transactions mentioned therein before the issuance of the impugned notice u/s 148 of the said Act, however, the petitioner had chosen not to respond to the said notice. - Reopening sustained - HC
Note: It is a system-generated summary and is for quick reference only.