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...
Section 143(1)(a) intimation lost its independent existence after the Assessing Officer reconsidered the same adjustments in scrutiny assessment under section 143(3) and granted relief on the rectification request. Applying the merger principle, the Tribunal held that the appeal against the intimation had become infructuous, and once that appeal was infructuous, the Revenue's further appeal against the first appellate order in the same matter was also infructuous. The Revenue's appeal was therefore dismissed on that basis.
Section 143(1)(a) intimation lost its independent existence after the Assessing Officer reconsidered the same adjustments in scrutiny assessment under section 143(3) and granted relief on the rectification request. Applying the merger principle, the Tribunal held that the appeal against the intimation had become infructuous, and once that appeal was infructuous, the Revenue's further appeal against the first appellate order in the same matter was also infructuous. The Revenue's appeal was therefore dismissed on that basis.
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