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 order u/s 143(3) r.w.s 263 - no intimation of DIN for the impugned order - The case of the assessee is that the communication, namely the assessment order is not only without mention of DIN in the body of the order, there is no material on the record mentioning the reason for non-issuance of DIN. Furthermore, the letter of intimation of DIN is also not within fifteen (15) working days of the issuance of the impugned assessment order - AT
Validity of assessment order u/s 143(3) r.w.s 263 - no intimation of DIN for the impugned order - The case of the assessee is that the communication, namely the assessment order is not only without mention of DIN in the body of the order, there is no material on the record mentioning the reason for non-issuance of DIN. Furthermore, the letter of intimation of DIN is also not within fifteen (15) working days of the issuance of the impugned assessment order - AT
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