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...
Where reassessment was initiated on the taxability of notional annual letting value of unsold flats, the Assessing Officer was required to make a focused enquiry and record a finding on that very issue. The reassessment order contained only a mechanical recital of notices and replies, with no verification, analysis or adjudication of the escapement question. Mere issue of notice did not show application of mind, and the defect was treated as a complete lack of enquiry rather than a mere inadequate enquiry. The section 263 revision was therefore upheld as the order was erroneous and prejudicial to the interests of the revenue, while the merits of the proposed addition were left open for fresh examination.
Where reassessment was initiated on the taxability of notional annual letting value of unsold flats, the Assessing Officer was required to make a focused enquiry and record a finding on that very issue. The reassessment order contained only a mechanical recital of notices and replies, with no verification, analysis or adjudication of the escapement question. Mere issue of notice did not show application of mind, and the defect was treated as a complete lack of enquiry rather than a mere inadequate enquiry. The section 263 revision was therefore upheld as the order was erroneous and prejudicial to the interests of the revenue, while the merits of the proposed addition were left open for fresh examination.
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