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...
Jurisdiction of the Income Tax authority to issue notice u/s 143[2] of the IT Act under the National Faceless Assessment Scheme (NaFAC / NFAC) - The provisions of Section 124 stipulate that when an assessee calls in question the jurisdiction of the AO - If the right to call in question the jurisdiction is left open to be raised at any stage, the proceedings will remain inconclusive and that could not have been the intendment of the legislature. Therefore, this Court must opine that the petitioner must fail - HC
Jurisdiction of the Income Tax authority to issue notice u/s 143[2] of the IT Act under the National Faceless Assessment Scheme (NaFAC / NFAC) - The provisions of Section 124 stipulate that when an assessee calls in question the jurisdiction of the AO - If the right to call in question the jurisdiction is left open to be raised at any stage, the proceedings will remain inconclusive and that could not have been the intendment of the legislature. Therefore, this Court must opine that the petitioner must fail - HC
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