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 against non-existing entity - scheme of the amalgamation and arrangement approved - The High Court acknowledges the petitioner's argument regarding the issuance of notices and assessment orders to a non-existent entity. It finds that the reassessment orders and notices cannot be sustained due to this fundamental flaw. As a result, the court quashes and sets aside the reassessment orders and notices. - The court observes that the reassessment orders failed to consider the legal consequences of the approved scheme of amalgamation and arrangement. - Consequently, the court quashed and set aside the reassessment orders and notices.
Reopening of assessment u/s 147 against non-existing entity - scheme of the amalgamation and arrangement approved - The High Court acknowledges the petitioner's argument regarding the issuance of notices and assessment orders to a non-existent entity. It finds that the reassessment orders and notices cannot be sustained due to this fundamental flaw. As a result, the court quashes and sets aside the reassessment orders and notices. - The court observes that the reassessment orders failed to consider the legal consequences of the approved scheme of amalgamation and arrangement. - Consequently, the court quashed and set aside the reassessment orders and notices.
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