Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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Revision u/s 263 - Assessee had to bear the loss as value of US dollar increased over the period since receipts of the remittance and date of export. In most of the cases of the remittance, assessee utilized the forward exchange contract made in the last year where value of the US$ was fixed which is lower than the value of US$ on the date of actual remittance. - Revenue has not brought any material on record to demonstrate that the view taken by the AO was an impermissible view and was contrary to law or was upon erroneous application of legal principles necessitating the exercising of Revisionary powers u/s 263 of the Act. - AT
Revision u/s 263 - Assessee had to bear the loss as value of US dollar increased over the period since receipts of the remittance and date of export. In most of the cases of the remittance, assessee utilized the forward exchange contract made in the last year where value of the US$ was fixed which is lower than the value of US$ on the date of actual remittance. - Revenue has not brought any material on record to demonstrate that the view taken by the AO was an impermissible view and was contrary to law or was upon erroneous application of legal principles necessitating the exercising of Revisionary powers u/s 263 of the Act. - AT
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