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...
Revision u/s 263 - period of limitation - whether the assessment order for AY 2015-16, issued on 31st March, 2023, was barred by the limitation prescribed in Section 153B? - The Supreme court noted that the impugned order was passed by the High Court without issuing a formal notice to the respondent-Department or calling for a response from them, despite the standing counsel for the Department being present in Court. - Considering this, the court disposed of the special leave petition, reserving liberty for the petitioner to raise contentions regarding jurisdictional error in relation to the limitation period before the appropriate authority.
Revision u/s 263 - period of limitation - whether the assessment order for AY 2015-16, issued on 31st March, 2023, was barred by the limitation prescribed in Section 153B? - The Supreme court noted that the impugned order was passed by the High Court without issuing a formal notice to the respondent-Department or calling for a response from them, despite the standing counsel for the Department being present in Court. - Considering this, the court disposed of the special leave petition, reserving liberty for the petitioner to raise contentions regarding jurisdictional error in relation to the limitation period before the appropriate authority.
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