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...
Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
