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 Assessment u/s 153C - Notice issued by any officer other than jurisdictional AO - the entire conspectus of the case, it appears that the AO had recorded the satisfaction note prior to assuming jurisdiction over the case of the assessee as the AO got charge over the case of the assessee on 02-09-2019 - CIT(A) is not justified in sustaining the action of the AO in holding that the AO has assumed proper jurisdiction to assess the case u/s. 153C - AT
Validity of Assessment u/s 153C - Notice issued by any officer other than jurisdictional AO - the entire conspectus of the case, it appears that the AO had recorded the satisfaction note prior to assuming jurisdiction over the case of the assessee as the AO got charge over the case of the assessee on 02-09-2019 - CIT(A) is not justified in sustaining the action of the AO in holding that the AO has assumed proper jurisdiction to assess the case u/s. 153C - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
