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 writ petition challenging the assessment order made u/s 143(3) read with Section 260 for the assessment year 2021-22. The petitioner argued that the assessment should have been done in a faceless manner as per the scheme notified on 29th March 2022. However, the court held that the notification invoking Section 151A was for faceless assessment of income escaping assessment u/s 147, and not for regular assessments u/s 143(3). The court observed that Section 144B provides a complete code for faceless assessment, which was not applicable in this case. The Assessing Officer found the purchases from suppliers doubtful, raising questions of fact. The court was disinclined to interfere on such factual issues and dismissed the petition.
The High Court dismissed the writ petition challenging the assessment order made u/s 143(3) read with Section 260 for the assessment year 2021-22. The petitioner argued that the assessment should have been done in a faceless manner as per the scheme notified on 29th March 2022. However, the court held that the notification invoking Section 151A was for faceless assessment of income escaping assessment u/s 147, and not for regular assessments u/s 143(3). The court observed that Section 144B provides a complete code for faceless assessment, which was not applicable in this case. The Assessing Officer found the purchases from suppliers doubtful, raising questions of fact. The court was disinclined to interfere on such factual issues and dismissed the petition.
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