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 to issue Reopening notice in metro city - It was established that the notice under Section 148 of the Act was issued by an Income Tax Officer (ITO), whereas the jurisdiction allegedly lay with the Assistant Commissioner or Deputy Commissioner of Income Tax. The Tribunal referred to relevant instructions indicating the appropriate jurisdiction based on income levels. Relying on the decision of the Hon'ble Bombay High Court in a similar case, the Tribunal held that the notice issued by the ITO was without jurisdiction and thus rendered the assessment order invalid.
Jurisdiction powers to issue Reopening notice in metro city - It was established that the notice under Section 148 of the Act was issued by an Income Tax Officer (ITO), whereas the jurisdiction allegedly lay with the Assistant Commissioner or Deputy Commissioner of Income Tax. The Tribunal referred to relevant instructions indicating the appropriate jurisdiction based on income levels. Relying on the decision of the Hon'ble Bombay High Court in a similar case, the Tribunal held that the notice issued by the ITO was without jurisdiction and thus rendered the assessment order invalid.
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