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 Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
Validity of Assessment u/s 153A - no search conducted u/s 132 and 132A as against the petitioner - Incriminating material from laptop - Electronic evidence admissibility - The High court concluded that the proceedings initiated u/s 153A, including the assessment order and demand notice based on the flawed panchnama and unauthorized search, were without jurisdiction and authority. Consequently, the court quashed the notice, assessment order, and demand notice, declaring the proceedings non-est and void ab initio.
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