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...
Transfer of case u/s 127 - sufficient material existed for transfer from Income Tax Office, Corporate Ward-2(3), Chennai to DCIT, Circle-4(4), Kolkata ('Central Circle'). Search and seizure u/s 132 revealed incriminating documents connecting petitioner's involvement in lottery business operations in West Bengal as sub-distributor, stockist, printing press, etc. Considering petitioner's reply, transfer ordered to centralize investigation along with eight other similar cases. Contentions of lack of opportunity or insufficient material rejected. Transfer for coordinated investigation in public interest permissible despite inconvenience. No prejudice caused as no adverse assessment order passed, only transfer u/s 127. Strict interpretation of taxing statute warranted. Writ petition dismissed.
Transfer of case u/s 127 - sufficient material existed for transfer from Income Tax Office, Corporate Ward-2(3), Chennai to DCIT, Circle-4(4), Kolkata ('Central Circle'). Search and seizure u/s 132 revealed incriminating documents connecting petitioner's involvement in lottery business operations in West Bengal as sub-distributor, stockist, printing press, etc. Considering petitioner's reply, transfer ordered to centralize investigation along with eight other similar cases. Contentions of lack of opportunity or insufficient material rejected. Transfer for coordinated investigation in public interest permissible despite inconvenience. No prejudice caused as no adverse assessment order passed, only transfer u/s 127. Strict interpretation of taxing statute warranted. Writ petition dismissed.
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