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 u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
Validity of Reopening of assessment u/s 147 - validity sanction u/s 151 - as argued approval has been applied for and granted mechanically - The High Court agreed with the petitioner, highlighting the casual manner in which approvals were granted, without proper verification or consideration of the material on record. Emphasizing the importance of exercising the power to reopen assessments with due diligence, the High Court quashed the impugned order and the consequent notice.
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