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 - Deduction U/s. 35D - effect of omission of word ‘industrial’ by the Finance Act, 2008 w.e.f 1/04/2009 - expenses incurred prior to 1/04/2009 - since assessee has fulfilled all the conditions stipulated under the Act for the residual period, there is no error in the order of the Ld. AO granting deduction - CIT is not right in his rem to invoke the revision provisions
Revision u/s 263 - Deduction U/s. 35D - effect of omission of word ‘industrial’ by the Finance Act, 2008 w.e.f 1/04/2009 - expenses incurred prior to 1/04/2009 - since assessee has fulfilled all the conditions stipulated under the Act for the residual period, there is no error in the order of the Ld. AO granting deduction - CIT is not right in his rem to invoke the revision provisions
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