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 - proceedings against the dissolved entity - notice in the name of petitioner LLP stood dissolved - the impugned notices and order are set aside. - Liberty is, however, given to AO to issue to Ms Ragini Mohan, who is the Legal Representative (LR) of the deceased managing partner fresh notice u/s 148A(b) of the Act. - HC
Validity of reopening of assessment - proceedings against the dissolved entity - notice in the name of petitioner LLP stood dissolved - the impugned notices and order are set aside. - Liberty is, however, given to AO to issue to Ms Ragini Mohan, who is the Legal Representative (LR) of the deceased managing partner fresh notice u/s 148A(b) of the Act. - HC
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