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...
Reassessment - disclouser of information - A parrot-like repetition of the statutory language without any substance would certainly not amount to satisfying the jurisdictional conditions but if coupled with the context is sufficiently capable of conveying the fact that there was failure on the part of the assessee, that should be sufficient compliance with the requirements of section 148(2) of the Act. - HC
Reassessment - disclouser of information - A parrot-like repetition of the statutory language without any substance would certainly not amount to satisfying the jurisdictional conditions but if coupled with the context is sufficiently capable of conveying the fact that there was failure on the part of the assessee, that should be sufficient compliance with the requirements of section 148(2) of the Act. - HC
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