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...
Revision under section 263 is sustainable only where the assessment order is both erroneous and prejudicial to the Revenue; a revisional authority cannot merely substitute its own view for a plausible assessment or direct additions without lawful re-examination. The Tribunal also noted that a provision for doubtful debts remained allowable where debtors were correspondingly reduced, foreign dividend deduction under section 80M was not overridden by section 115BBD, festival and pooja expenses supported by business records were not personal, taxes paid under protest could still qualify on actual payment, GST credit reversal loss from fire required factual support, and section 54EC relief was not denied merely because section 50 applied for computation.
Revision under section 263 is sustainable only where the assessment order is both erroneous and prejudicial to the Revenue; a revisional authority cannot merely substitute its own view for a plausible assessment or direct additions without lawful re-examination. The Tribunal also noted that a provision for doubtful debts remained allowable where debtors were correspondingly reduced, foreign dividend deduction under section 80M was not overridden by section 115BBD, festival and pooja expenses supported by business records were not personal, taxes paid under protest could still qualify on actual payment, GST credit reversal loss from fire required factual support, and section 54EC relief was not denied merely because section 50 applied for computation.
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