Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Revision u/s 263 - Addition u/s 68 - unexplained share capital and premium - The assessee had not only submitted all the details and evidences to prove the share capital raised but has also produced all the directors of shareholder companies who were examined on oath - AO has verified the bank statements, books of accounts, copy of share application and allotment forms, etc. were checked and placed in the records. - PCIT could not have usurped the revisional jurisdiction u/s 263 of the Act without satisfying the conditions - AT
Revision u/s 263 - Addition u/s 68 - unexplained share capital and premium - The assessee had not only submitted all the details and evidences to prove the share capital raised but has also produced all the directors of shareholder companies who were examined on oath - AO has verified the bank statements, books of accounts, copy of share application and allotment forms, etc. were checked and placed in the records. - PCIT could not have usurped the revisional jurisdiction u/s 263 of the Act without satisfying the conditions - AT
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