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 - jurisdiction of notice issuing authority - A jurisdiction can neither be waived nor created even by consent and even by submitting to jurisdiction, an Assessee cannot confer upon any jurisdictional authority, something which he lacked inherently. Therefore the contention of DR regarding applicability of section 292BB also does not hold water in favour of the revenue. - AT
Validity of reopening of assessment - jurisdiction of notice issuing authority - A jurisdiction can neither be waived nor created even by consent and even by submitting to jurisdiction, an Assessee cannot confer upon any jurisdictional authority, something which he lacked inherently. Therefore the contention of DR regarding applicability of section 292BB also does not hold water in favour of the revenue. - AT
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