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 153C/143(3) against Settlement Commission order - The Tribunal found the reassessment to infringe upon the principles laid out by the ITSC, which had already settled the income at 8% of the receipts from the water pipeline project. The reassessment was deemed impermissible in law, rendering the impugned order dated 30.12.2019 passed u/s 153C/153A/143(3) as invalid. Consequently, all additions made therein were deleted.
Validity of assessment order passed u/s 153C/143(3) against Settlement Commission order - The Tribunal found the reassessment to infringe upon the principles laid out by the ITSC, which had already settled the income at 8% of the receipts from the water pipeline project. The reassessment was deemed impermissible in law, rendering the impugned order dated 30.12.2019 passed u/s 153C/153A/143(3) as invalid. Consequently, all additions made therein were deleted.
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