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 draft assessment order u/s 144C(1) - difference in numbers in closing and opening stock of Lingerie - The show cause notice lacked specific quantification of proposed additions to income - The High court directed that the draft assessment order be treated as a show cause notice, allowing the petitioner to submit a reply within three weeks. The assessing officer was instructed to provide a reasonable opportunity, including a personal hearing through video conferencing, before issuing a fresh draft assessment order.
Validity of draft assessment order u/s 144C(1) - difference in numbers in closing and opening stock of Lingerie - The show cause notice lacked specific quantification of proposed additions to income - The High court directed that the draft assessment order be treated as a show cause notice, allowing the petitioner to submit a reply within three weeks. The assessing officer was instructed to provide a reasonable opportunity, including a personal hearing through video conferencing, before issuing a fresh draft assessment order.
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