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...
Validity of Proceeding u/s 158BC - satisfaction was not recorded before completion of assessment proceeding - the order passed by the AO as well as the CIT (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Apex Court.
Validity of Proceeding u/s 158BC - satisfaction was not recorded before completion of assessment proceeding - the order passed by the AO as well as the CIT (Appeals) has been set aside by the Tribunal merely on the ground that the satisfaction has not been recorded before completion of the assessment proceedings. The aforesaid finding is contrary to law laid down by the Apex Court.
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