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 u/s 144C - Period of limitation - The Ld. CIT-DR argued that the delay was due to the assessee's failure to participate in the verification process as directed by the DRP. However, the Tribunal noted that sub-section (8) of section 144C precludes the DRP from setting aside any proposed variation or issuing any direction for further enquiry and passing of the assessment order. The AO was mandated to complete the assessment within the specified time limit without providing any further opportunity of being heard to the assessee. - The Tribunal concluded that the final assessment order passed by the AO was barred by limitation and, therefore, null in the eyes of law.
Assessment u/s 144C - Period of limitation - The Ld. CIT-DR argued that the delay was due to the assessee's failure to participate in the verification process as directed by the DRP. However, the Tribunal noted that sub-section (8) of section 144C precludes the DRP from setting aside any proposed variation or issuing any direction for further enquiry and passing of the assessment order. The AO was mandated to complete the assessment within the specified time limit without providing any further opportunity of being heard to the assessee. - The Tribunal concluded that the final assessment order passed by the AO was barred by limitation and, therefore, null in the eyes of law.
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