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...
The High Court dismissed the petitioner's challenge to the reopening of assessment u/s 147, citing the petitioner's delayed compliance with notice u/s 148 and failure to challenge the re-assessment notice or reasons for reassessment. The Court held that the petitioner's failure to avail the statutory appeal remedy precluded invoking writ jurisdiction. The Court noted factual issues requiring adjudication beyond Article 226 scope, such as delay in statutory audit and compliance with Co-operative Societies Act. The petitioner's contention on the doctrine of merger was deemed misconceived. The Court refrained from opining on audit merits, urging the petitioner to pursue appellate remedy. The Court dismissed the writ applications, advising the petitioner to challenge the orders before the appellate authority, with the possibility of condoning the limitation period for filing appeals.
The High Court dismissed the petitioner's challenge to the reopening of assessment u/s 147, citing the petitioner's delayed compliance with notice u/s 148 and failure to challenge the re-assessment notice or reasons for reassessment. The Court held that the petitioner's failure to avail the statutory appeal remedy precluded invoking writ jurisdiction. The Court noted factual issues requiring adjudication beyond Article 226 scope, such as delay in statutory audit and compliance with Co-operative Societies Act. The petitioner's contention on the doctrine of merger was deemed misconceived. The Court refrained from opining on audit merits, urging the petitioner to pursue appellate remedy. The Court dismissed the writ applications, advising the petitioner to challenge the orders before the appellate authority, with the possibility of condoning the limitation period for filing appeals.
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