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 proceedings - assessing authority not considering the reply-cum-objection filed by the petitioner - Period of limitation where monetary limit is below threshold of Rs. 50 lakhs - Joint Ownership of the property - The High Court quashed the entire enquiry proceeding, including the order under section 148A(d) of the Act and the notice issued under Section 148, deeming them beyond jurisdiction and barred by limitation. The court allowed the petitioner's application, emphasizing the procedural lapses and the incorrect application of the law by the tax department in this case.
Validity of reopening proceedings - assessing authority not considering the reply-cum-objection filed by the petitioner - Period of limitation where monetary limit is below threshold of Rs. 50 lakhs - Joint Ownership of the property - The High Court quashed the entire enquiry proceeding, including the order under section 148A(d) of the Act and the notice issued under Section 148, deeming them beyond jurisdiction and barred by limitation. The court allowed the petitioner's application, emphasizing the procedural lapses and the incorrect application of the law by the tax department in this case.
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