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 - 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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