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 - estimation of income on bogus purchases - Keeping in view the applicable VAT rate, Ld. AO estimated a further addition of 1.6% against these purchases. - Merely because Ld. Pr. CIT held a view that the estimation should have been at higher rates or entire purchase should have been disallowed, the same would not make the order erroneous - AT
Revision u/s 263 - estimation of income on bogus purchases - Keeping in view the applicable VAT rate, Ld. AO estimated a further addition of 1.6% against these purchases. - Merely because Ld. Pr. CIT held a view that the estimation should have been at higher rates or entire purchase should have been disallowed, the same would not make the order erroneous - AT
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