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 - Notice u/s 148-A - Reason to believe - Source of information is not relevant. What is relevant is the tangible material against the appellant. The petitioner did not even submit bank statements or the books of accounts. - There is, prima facie, some material on the basis of which the Department could reopen the case. - Writ Petition dismissed - Notice sustained - HC
Reopening of assessment u/s 147 - Notice u/s 148-A - Reason to believe - Source of information is not relevant. What is relevant is the tangible material against the appellant. The petitioner did not even submit bank statements or the books of accounts. - There is, prima facie, some material on the basis of which the Department could reopen the case. - Writ Petition dismissed - Notice sustained - HC
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