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 held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
HC held that for calculating the 6-year limitation period under Section 153C(1), the relevant date is 30.06.2022, when documents were collected from the petitioner, not the search date of 10.11.2020. The show cause notice dated 30.12.2024 is within limitation. The petitioner retains the right to respond to the notice and contest proceedings. Despite a prior settlement, the Department retains liberty to pursue further action if new materials emerge. The writ petitions were consequently dismissed, finding no merit in the petitioner's limitation arguments.
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