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...
Writ petition challenging reopening of assessment u/s 147 for income chargeable u/s 5(2) rejected. Petitioner failed to establish with documentary evidence husband's non-resident Indian status and genuineness of sources of funds transferred from NRE account to domestic account. Court reluctant to interfere in assessment orders under Article 226 when effective alternative remedy available, especially involving disputed questions of fact. Petitioner granted liberty to file appeal within three weeks from order copy receipt, without limitation objection, subject to compliance with appeal conditions including pre-deposit, if any. Merits not examined, observation limited to maintainability of writ petition.
Writ petition challenging reopening of assessment u/s 147 for income chargeable u/s 5(2) rejected. Petitioner failed to establish with documentary evidence husband's non-resident Indian status and genuineness of sources of funds transferred from NRE account to domestic account. Court reluctant to interfere in assessment orders under Article 226 when effective alternative remedy available, especially involving disputed questions of fact. Petitioner granted liberty to file appeal within three weeks from order copy receipt, without limitation objection, subject to compliance with appeal conditions including pre-deposit, if any. Merits not examined, observation limited to maintainability of writ petition.
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