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 court allowed the application seeking permission to complete the assessment for the year 2019-20 in respect of the assessee petitioner. However, the court imposed a condition that if the assessment is adverse to the petitioner, it shall not be enforced and shall be subject to further orders on the petition. All contentions of the parties regarding the assessment were expressly kept open. The court's decision was based on a previous order passed by a coordinate bench in a similar case, where the state was permitted to proceed with the assessment for the year 2018-19 to avoid it becoming time-barred.
The court allowed the application seeking permission to complete the assessment for the year 2019-20 in respect of the assessee petitioner. However, the court imposed a condition that if the assessment is adverse to the petitioner, it shall not be enforced and shall be subject to further orders on the petition. All contentions of the parties regarding the assessment were expressly kept open. The court's decision was based on a previous order passed by a coordinate bench in a similar case, where the state was permitted to proceed with the assessment for the year 2018-19 to avoid it becoming time-barred.
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