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 - bogus purchases - the assessment order does not indicate that AO had examined the genuineness of the purchase transaction in the light of the audited accounts of the assessee. The amount was shown to have been outstanding goes unverified and the assessment order is silent on this aspect. - PCIT rightly assumed jurisdiction
Revision u/s 263 - bogus purchases - the assessment order does not indicate that AO had examined the genuineness of the purchase transaction in the light of the audited accounts of the assessee. The amount was shown to have been outstanding goes unverified and the assessment order is silent on this aspect. - PCIT rightly assumed jurisdiction
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