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...
HC upheld validity of assessment order under s.147 read with s.144B, finding proper approval under s.151. Court confirmed Range Head and CIT/PCIT had appropriately endorsed AO's recorded reasons for scrutiny notice under s.148. Review of computerized order details demonstrated requisite approvals obtained at each stage of faceless assessment. Finding no jurisdictional error, HC declined to exercise writ jurisdiction. Petitioner directed to pursue statutory appeal remedy for AY 2013-14, with time spent in writ proceedings eligible for consideration in any delay condonation application.
HC upheld validity of assessment order under s.147 read with s.144B, finding proper approval under s.151. Court confirmed Range Head and CIT/PCIT had appropriately endorsed AO's recorded reasons for scrutiny notice under s.148. Review of computerized order details demonstrated requisite approvals obtained at each stage of faceless assessment. Finding no jurisdictional error, HC declined to exercise writ jurisdiction. Petitioner directed to pursue statutory appeal remedy for AY 2013-14, with time spent in writ proceedings eligible for consideration in any delay condonation application.
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