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 article addresses the requirement that assumption of jurisdiction under section 153C requires a contemporaneous, written and year specific satisfaction by the Assessing Officer linking seized material to each assessment year; consolidated or blanket satisfaction spanning multiple years without year wise nexus is legally insufficient. Applying this principle, assessments founded on such undifferentiated satisfaction notes are unsustainable and liable to be quashed as void ab initio where no year specific incriminating material is shown to relate to the assessee for the years under consideration.
The article addresses the requirement that assumption of jurisdiction under section 153C requires a contemporaneous, written and year specific satisfaction by the Assessing Officer linking seized material to each assessment year; consolidated or blanket satisfaction spanning multiple years without year wise nexus is legally insufficient. Applying this principle, assessments founded on such undifferentiated satisfaction notes are unsustainable and liable to be quashed as void ab initio where no year specific incriminating material is shown to relate to the assessee for the years under consideration.
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