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 E-Assessment u/s 147 read with Section 144B - The petitioners permitted the authorities to proceed under Section 147 by responding to the notice. It is only after passing of the assessment orders that is now sought to be urged that the re-opening was without jurisdiction and it ought to have been only u/s 153C of the Act of 1961. - we are not inclined to invoke extra ordinary jurisdiction in favour of the petitioners especially since an efficacious statutory remedy is available. - HC
Validity of E-Assessment u/s 147 read with Section 144B - The petitioners permitted the authorities to proceed under Section 147 by responding to the notice. It is only after passing of the assessment orders that is now sought to be urged that the re-opening was without jurisdiction and it ought to have been only u/s 153C of the Act of 1961. - we are not inclined to invoke extra ordinary jurisdiction in favour of the petitioners especially since an efficacious statutory remedy is available. - HC
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