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...
ITAT quashed the assessment order due to procedural non-compliance. The AO improperly initiated reassessment under Section 147 instead of Section 153C when loose papers suggesting a potential Rs.13 Cr payment were discovered during a third-party search. The tribunal found the AO lacked sufficient material evidence to substantiate the undisclosed income claim. Additionally, the absence of a mandatory Section 143(2) notice rendered the assessment unsustainable. Consequently, the tribunal deleted the income addition and accompanying penalty under Section 271D, emphasizing strict adherence to prescribed legal procedures in tax proceedings.
ITAT quashed the assessment order due to procedural non-compliance. The AO improperly initiated reassessment under Section 147 instead of Section 153C when loose papers suggesting a potential Rs.13 Cr payment were discovered during a third-party search. The tribunal found the AO lacked sufficient material evidence to substantiate the undisclosed income claim. Additionally, the absence of a mandatory Section 143(2) notice rendered the assessment unsustainable. Consequently, the tribunal deleted the income addition and accompanying penalty under Section 271D, emphasizing strict adherence to prescribed legal procedures in tax proceedings.
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