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 notice issued u/s 148A - not signed either physically or digitally - minimum period of seven days prescribed u/s 148A(b) not provided - - The High court, in its analysis, referred to precedents and held that the notices were indeed invalid due to lack of signature and non-compliance with prescribed time periods. Consequently, the court quashed the impugned notices and orders while reserving liberty for the respondents to initiate proceedings in accordance with the law.
Validity of reopening notice issued u/s 148A - not signed either physically or digitally - minimum period of seven days prescribed u/s 148A(b) not provided - - The High court, in its analysis, referred to precedents and held that the notices were indeed invalid due to lack of signature and non-compliance with prescribed time periods. Consequently, the court quashed the impugned notices and orders while reserving liberty for the respondents to initiate proceedings in accordance with the law.
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