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 HC dismissed the petition filed by the petitioner, a government company, against compulsory selection of its return for scrutiny by the Assessing Officer. The HC held that the CBDT guidelines for compulsory scrutiny did not preclude random selection by the AO. It rejected the contention of violation of natural justice, as the petitioner did not seek personal hearing while filing online reply. The HC found no reason to interfere under Article 226.
The HC dismissed the petition filed by the petitioner, a government company, against compulsory selection of its return for scrutiny by the Assessing Officer. The HC held that the CBDT guidelines for compulsory scrutiny did not preclude random selection by the AO. It rejected the contention of violation of natural justice, as the petitioner did not seek personal hearing while filing online reply. The HC found no reason to interfere under Article 226.
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