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 reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
Validity of reopening of assessment - Sanction for issue of notice u/s 151 - The High Court found that the AO had acted based on borrowed satisfaction and lacked independent application of mind. Additionally, the court ruled that the approval granted was merely mechanical and did not involve proper consideration. Consequently, the court upheld the decision of the ITAT to quash the reopening proceedings and notice issued under Section 148 of the Act, dismissing the appeal of the Revenue.
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