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 assessment order passed u/s 144C - due to oversight/inadvertence Petitioner did not inform the AO within 30 days period prescribed under Sub-section (2) of Section 144C that it had filed objection by way of an email - The court disposes of the petition, setting aside the assessment order and remitting the matter to the DRP for consideration of the petitioner's objections. The Assessing Officer is directed to take further steps in accordance with the law after the DRP passes its order.
Validity of assessment order passed u/s 144C - due to oversight/inadvertence Petitioner did not inform the AO within 30 days period prescribed under Sub-section (2) of Section 144C that it had filed objection by way of an email - The court disposes of the petition, setting aside the assessment order and remitting the matter to the DRP for consideration of the petitioner's objections. The Assessing Officer is directed to take further steps in accordance with the law after the DRP passes its order.
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