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 - estimation of income - when the income assessed by the AO was far more than the income returned by the assessee and all the investments made by the assessee stood explained - estimation of income adopted by the AO, being one of the recognized methods of determination of income, could not be found fault - not find any perversity in the finding - no substantial questions of law
Revision u/s 263 - estimation of income - when the income assessed by the AO was far more than the income returned by the assessee and all the investments made by the assessee stood explained - estimation of income adopted by the AO, being one of the recognized methods of determination of income, could not be found fault - not find any perversity in the finding - no substantial questions of law
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