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 u/s 263 - In the instant case the order of the AO may be prejudicial to the interest of the revenue but it cannot be said to be erroneous since various judicial decisions support the case of the assessee that the assessee is entitled to deduction u/s.54F in respect of 2 adjacent units - order of revision set aside - AT
Revision u/s 263 - In the instant case the order of the AO may be prejudicial to the interest of the revenue but it cannot be said to be erroneous since various judicial decisions support the case of the assessee that the assessee is entitled to deduction u/s.54F in respect of 2 adjacent units - order of revision set aside - AT
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