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 - AO failed to apply his mind to the case in all perspective in terms of conditions contemplated in provisions u/s. 54F - He accepted the claim of assessee in the absence of any inquiry - Revision order sustained.
Revision u/s 263 - AO failed to apply his mind to the case in all perspective in terms of conditions contemplated in provisions u/s. 54F - He accepted the claim of assessee in the absence of any inquiry - Revision order sustained.
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