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 - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
Reopening of assessment - The Appellate Tribunal cited the CBDT's instruction clarifying the judgment of the Hon’ble Supreme Court, stating that notices cannot be issued for certain assessment years where the income escaping assessment is less than fifty lakh rupees. Since the escaped income in the present case was Rs. 29 Lacs falling below the threshold, the Tribunal quashed the notice issued u/s 148 of the Act.
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