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...
Jurisdiction - powers of AO to re-assess the escape turnover - Power of suo moto revision. - The High court found that the respondent No. 3 (Additional Commissioner of Taxes) exceeded his jurisdiction by revising the assessment orders without conclusively determining that the original orders were erroneous and prejudicial to the interests of revenue based on existing records. - The court also noted the anomaly where the revision under Section 20 of the Nagaland Act also covered aspects under the Central Sales Tax Act, 1956, which was beyond the jurisdiction of the respondent No. 3 under the said Section. - Revision orders quashed.
Jurisdiction - powers of AO to re-assess the escape turnover - Power of suo moto revision. - The High court found that the respondent No. 3 (Additional Commissioner of Taxes) exceeded his jurisdiction by revising the assessment orders without conclusively determining that the original orders were erroneous and prejudicial to the interests of revenue based on existing records. - The court also noted the anomaly where the revision under Section 20 of the Nagaland Act also covered aspects under the Central Sales Tax Act, 1956, which was beyond the jurisdiction of the respondent No. 3 under the said Section. - Revision orders quashed.
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