Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Transfer pricing comparability was addressed by excluding Unik Techno Systems Pvt. Ltd. as a valid comparable because functional dissimilarity (manufacturer of battery-production machines versus assessee's activities) rendered it unsuitable; the AO/TPO is directed to recompute ALP without that entity. Separately, the appellate body admitted fresh grounds contending that an excise duty exemption may constitute a non taxable capital receipt and remitted that substantive issue to the assessing officer for factual verification of scheme intent, eligibility and amounts, treatment under normal provisions and AMT, and for fresh decision after affording the assessee opportunity to be heard.
Transfer pricing comparability was addressed by excluding Unik Techno Systems Pvt. Ltd. as a valid comparable because functional dissimilarity (manufacturer of battery-production machines versus assessee's activities) rendered it unsuitable; the AO/TPO is directed to recompute ALP without that entity. Separately, the appellate body admitted fresh grounds contending that an excise duty exemption may constitute a non taxable capital receipt and remitted that substantive issue to the assessing officer for factual verification of scheme intent, eligibility and amounts, treatment under normal provisions and AMT, and for fresh decision after affording the assessee opportunity to be heard.
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