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 - SCN related to taxability of unsold flats - amendment introduced by the Finance Act, 2017 w.e.f. 1/4/2018 - When the assessment order was passed on 31.03.2016, relevant provision has not even been brought into statute book - AO cannot be expected to apply the same - the assessment order cannot be said to be erroneous and prejudicial to the interest of the Revenue - order of the CIT quashed
Revision u/s 263 - SCN related to taxability of unsold flats - amendment introduced by the Finance Act, 2017 w.e.f. 1/4/2018 - When the assessment order was passed on 31.03.2016, relevant provision has not even been brought into statute book - AO cannot be expected to apply the same - the assessment order cannot be said to be erroneous and prejudicial to the interest of the Revenue - order of the CIT quashed
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