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 - capital gain earned by the assessee on sale of the shares has not been offered for the Book Profit tax under section 115JB - since no proper inquiry was conducted by the AO, the order is erroneous so far as it is prejudicial to the interest of the revenue.
Revision u/s 263 - capital gain earned by the assessee on sale of the shares has not been offered for the Book Profit tax under section 115JB - since no proper inquiry was conducted by the AO, the order is erroneous so far as it is prejudicial to the interest of the revenue.
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