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 o Ex parte scrutiny assessment order u/s 143(3) r.w.s. 144B - The court highlighted the importance of oral hearing in assessment proceedings, stating that it is essential for an effective discussion and a reasoned conclusion by the Assessing Officer. It was emphasized that assessment orders should be passed after giving the assessee an opportunity to present their case, and oral hearing remains a near-mandatory requirement to ensure a just and proper order.
Validity of o Ex parte scrutiny assessment order u/s 143(3) r.w.s. 144B - The court highlighted the importance of oral hearing in assessment proceedings, stating that it is essential for an effective discussion and a reasoned conclusion by the Assessing Officer. It was emphasized that assessment orders should be passed after giving the assessee an opportunity to present their case, and oral hearing remains a near-mandatory requirement to ensure a just and proper order.
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