Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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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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