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 of an assessment is warranted where the Assessing Officer fails to apply the statutory deeming provisions to additions for undisclosed investment and unexplained cash, omits the applicable special tax rate, and does not consider penalty proceedings. An order is erroneous when based on incorrect facts or law, made without due application of mind, or contrary to natural justice. It is prejudicial to revenue where lawful tax is not realised. The revisional authority may set aside such an assessment, direct further inquiry, and require reassessment under the correct provisions after providing an opportunity of being heard.
Revision of an assessment is warranted where the Assessing Officer fails to apply the statutory deeming provisions to additions for undisclosed investment and unexplained cash, omits the applicable special tax rate, and does not consider penalty proceedings. An order is erroneous when based on incorrect facts or law, made without due application of mind, or contrary to natural justice. It is prejudicial to revenue where lawful tax is not realised. The revisional authority may set aside such an assessment, direct further inquiry, and require reassessment under the correct provisions after providing an opportunity of being heard.
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