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...
Order u/s 148A(b) as passed against the petitioner in respect of the old PAN card - The Court noted that both the old and the new PAN cards of the petitioner were active, and since the old PAN card was used for transactions in the assessment year 2018-19, and the proceedings related to it were pending, the request for deletion of the old PAN could not be considered. The petitioner had transitioned from the old PAN card to a new one but faced issues due to an assessment order pertaining to the old PAN for unexplained money u/s 69A of the Income Tax Act. The Court directed that if the petitioner files an appeal using the old PAN, it should be processed in accordance with the law.
Order u/s 148A(b) as passed against the petitioner in respect of the old PAN card - The Court noted that both the old and the new PAN cards of the petitioner were active, and since the old PAN card was used for transactions in the assessment year 2018-19, and the proceedings related to it were pending, the request for deletion of the old PAN could not be considered. The petitioner had transitioned from the old PAN card to a new one but faced issues due to an assessment order pertaining to the old PAN for unexplained money u/s 69A of the Income Tax Act. The Court directed that if the petitioner files an appeal using the old PAN, it should be processed in accordance with the law.
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