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 allowed the petitioner's appeal, quashing the AO's reassessment order under Section 148A(d). The court found the order was passed without application of mind, highlighting internal contradictions where the AO first acknowledged the income tax return's filing, then subsequently claimed no return was submitted. The decision emphasized the petitioner's submission of bank statements documenting funds borrowed from his father for cryptocurrency purchase, which were undisputed. The reassessment order was deemed legally unsustainable and was set aside, providing relief to the taxpayer by invalidating the reopening of the assessment.
HC allowed the petitioner's appeal, quashing the AO's reassessment order under Section 148A(d). The court found the order was passed without application of mind, highlighting internal contradictions where the AO first acknowledged the income tax return's filing, then subsequently claimed no return was submitted. The decision emphasized the petitioner's submission of bank statements documenting funds borrowed from his father for cryptocurrency purchase, which were undisputed. The reassessment order was deemed legally unsustainable and was set aside, providing relief to the taxpayer by invalidating the reopening of the assessment.
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