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 - Approval of PCIT u/s 151 - The Tribunal acknowledged the Assessee's argument regarding the mechanical approval granted by the PCIT. They referred to precedents where similar approvals were deemed invalid due to lack of meaningful application of mind. Citing relevant case law, the Tribunal concluded that the approval in this case, given with a simple "Yes, I am satisfied," lacked due application of mind by the approving authority. Therefore, the Tribunal allowed the ground raised by the Assessee regarding the validity of the reassessment proceedings.
Validity of reopening of assessment - Approval of PCIT u/s 151 - The Tribunal acknowledged the Assessee's argument regarding the mechanical approval granted by the PCIT. They referred to precedents where similar approvals were deemed invalid due to lack of meaningful application of mind. Citing relevant case law, the Tribunal concluded that the approval in this case, given with a simple "Yes, I am satisfied," lacked due application of mind by the approving authority. Therefore, the Tribunal allowed the ground raised by the Assessee regarding the validity of the reassessment proceedings.
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