Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Revision u/s 263 - deduction under section 54B - No doubt the assessee declared capital gain but, whether its exemption can be claimed on purchase of other agriculture land, is not at all examined by the AO - the ld. PCIT validly assumed his jurisdiction for exercising his power u/s 263 by taking view that the order passed by AO is erroneous and in so far as prejudicial to the interest of justice. - Facts remained that the ld. PCIT passed the impugned order without considering various pleas of the assessee raised in its reply. - Matter restored back - AT
Revision u/s 263 - deduction under section 54B - No doubt the assessee declared capital gain but, whether its exemption can be claimed on purchase of other agriculture land, is not at all examined by the AO - the ld. PCIT validly assumed his jurisdiction for exercising his power u/s 263 by taking view that the order passed by AO is erroneous and in so far as prejudicial to the interest of justice. - Facts remained that the ld. PCIT passed the impugned order without considering various pleas of the assessee raised in its reply. - Matter restored back - AT
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