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...
Reopening of assessment - reasons to believe - On the issue of disclosure and compliance with TDS provisions, the court found that the petitioner had indeed disclosed all material facts during the original assessment proceedings. The transactions in question were merely transfers of funds on instructions from the horse owners. - The court held that the objections raised by the petitioner against the reassessment were valid. The authorities had failed to consider the full scope of the disclosures made during the original assessments and erroneously pursued reassessment.
Reopening of assessment - reasons to believe - On the issue of disclosure and compliance with TDS provisions, the court found that the petitioner had indeed disclosed all material facts during the original assessment proceedings. The transactions in question were merely transfers of funds on instructions from the horse owners. - The court held that the objections raised by the petitioner against the reassessment were valid. The authorities had failed to consider the full scope of the disclosures made during the original assessments and erroneously pursued reassessment.
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