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 held that the second notice issued u/s 148A(b) was a standalone notice, not a continuation of the first notice. The information on which the notices were based was completely different. As the second standalone notice was issued beyond the 3-year period stipulated u/s 149(1)(a) for reopening assessment where escaped income is less than Rs. 50 lakhs, it was barred by limitation. Consequently, the HC set aside the impugned order u/s 148A(d) and the notice u/s 148A(b), deciding in favor of the assessee.
The HC held that the second notice issued u/s 148A(b) was a standalone notice, not a continuation of the first notice. The information on which the notices were based was completely different. As the second standalone notice was issued beyond the 3-year period stipulated u/s 149(1)(a) for reopening assessment where escaped income is less than Rs. 50 lakhs, it was barred by limitation. Consequently, the HC set aside the impugned order u/s 148A(d) and the notice u/s 148A(b), deciding in favor of the assessee.
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