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...
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
