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 - sale of agriculture land or not - AO asked for the explanation but never made any enquiry or verification of assessee claim and allowed the relief - Explanation 2 to section 263 is clearly attracted i.e deemed to be erroneous and prejudicial to the interests of the Revenue
Revision u/s 263 - sale of agriculture land or not - AO asked for the explanation but never made any enquiry or verification of assessee claim and allowed the relief - Explanation 2 to section 263 is clearly attracted i.e deemed to be erroneous and prejudicial to the interests of the Revenue
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