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 reopening of assessment u/s 147 - Mandation of obtaining sanction of JCIT - addition made u/s 68 - It is a well settled legal principle that when a statutory provision requires a certain act to be done by a particular authority in a particular manner, it should be done by that authority in that manner only. Any other authority, be it higher or inferior, cannot substitute the authority prescribed under the statute. The legal principle on this aspect is very much clear and leaves no room for doubt. - AT
Validity of reopening of assessment u/s 147 - Mandation of obtaining sanction of JCIT - addition made u/s 68 - It is a well settled legal principle that when a statutory provision requires a certain act to be done by a particular authority in a particular manner, it should be done by that authority in that manner only. Any other authority, be it higher or inferior, cannot substitute the authority prescribed under the statute. The legal principle on this aspect is very much clear and leaves no room for doubt. - AT
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