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 addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
The High Court addressed the validity of an assessment u/s 153A and the jurisdiction for assessment proceedings transfer. The petitioner challenged the transfer from Sangli to Kozhikode, citing lack of mandatory notice and hearing u/s 127(2) and absence of a Document Identification Number (DIN) in the order. The Court found that notice was duly served, giving the petitioner an opportunity to respond, which was not utilized. The absence of DIN is being considered by the Supreme Court, but the transfer was deemed valid as the petitioner's business and recovery were within Kozhikode's jurisdiction. The Court dismissed the writ petition, finding no errors in the proceedings.
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