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...
Assessment against non existent company - name of company struck off by ROC - Assessment based on Seized Materials - The Tribunal noted that the Assessing Officer was aware of the company's non-existence but proceeded with the assessment. It ruled that the assessment orders passed in the name of a non-existing company were void ab initio, as they lacked jurisdictional validity. Consequently, the Tribunal quashed the entire assessment proceedings and allowed the cross objections filed by the assessee, dismissing the appeals filed by the Revenue.
Assessment against non existent company - name of company struck off by ROC - Assessment based on Seized Materials - The Tribunal noted that the Assessing Officer was aware of the company's non-existence but proceeded with the assessment. It ruled that the assessment orders passed in the name of a non-existing company were void ab initio, as they lacked jurisdictional validity. Consequently, the Tribunal quashed the entire assessment proceedings and allowed the cross objections filed by the assessee, dismissing the appeals filed by the Revenue.
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