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 - Period of limitation - if the issue on which the proceedings u/s 263 is initiated is not a subject matter of the assessment order passed u/s 143(3) r/w 147, then the limitation period has to be reckoned from the original assessment order passed u/s 143(3) or if the return of income was processed u/s 143(1), then from the date of intimation u/s 143(1)
Revision u/s 263 - Period of limitation - if the issue on which the proceedings u/s 263 is initiated is not a subject matter of the assessment order passed u/s 143(3) r/w 147, then the limitation period has to be reckoned from the original assessment order passed u/s 143(3) or if the return of income was processed u/s 143(1), then from the date of intimation u/s 143(1)
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