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 examined the grievances of an assessee against the Assessment Officer's rejection of their claim for High-Pitch scrutiny assessment without providing reasons. The court held that while the Local Committee must submit a report determining whether the order qualifies as High-Pitch assessment, there is no provision requiring the committee to provide an opportunity for hearing to the assessee. The assessee's claim of being heard by the Local Committee was deemed baseless, as the committee's purpose is to address genuine grievances efficiently, not serve as an alternative dispute resolution forum. The court concluded that if the Local Committee determines the case is not High-Pitch assessment, the assessee cannot compel the committee to examine and decide the case.
The High Court examined the grievances of an assessee against the Assessment Officer's rejection of their claim for High-Pitch scrutiny assessment without providing reasons. The court held that while the Local Committee must submit a report determining whether the order qualifies as High-Pitch assessment, there is no provision requiring the committee to provide an opportunity for hearing to the assessee. The assessee's claim of being heard by the Local Committee was deemed baseless, as the committee's purpose is to address genuine grievances efficiently, not serve as an alternative dispute resolution forum. The court concluded that if the Local Committee determines the case is not High-Pitch assessment, the assessee cannot compel the committee to examine and decide the case.
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