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 u/s 147 - The petitioner had initially failed to file income tax returns but later submitted various documents in response to notices received under the Income Tax Act. Despite this, the assessment order did not consider the documents submitted by the petitioner, nor did it provide reasons for the proposed variations. The court set aside the impugned order and remanded the matter to the tax authorities for reconsideration.
Reopening of assessment u/s 147 - The petitioner had initially failed to file income tax returns but later submitted various documents in response to notices received under the Income Tax Act. Despite this, the assessment order did not consider the documents submitted by the petitioner, nor did it provide reasons for the proposed variations. The court set aside the impugned order and remanded the matter to the tax authorities for reconsideration.
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