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 by CIT - bogus loss on shares - penny stock transactions - Reliance on audit objection given by the audit party - As safely concluded that the ld. AO had indeed taken a possible view on the matter. PCIT merely because he has got a different view on the same set of facts cannot try to substitute his view in place of the view already taken by the ld. AO by invoking his revision jurisdiction u/s.263. - AT
Revision u/s 263 by CIT - bogus loss on shares - penny stock transactions - Reliance on audit objection given by the audit party - As safely concluded that the ld. AO had indeed taken a possible view on the matter. PCIT merely because he has got a different view on the same set of facts cannot try to substitute his view in place of the view already taken by the ld. AO by invoking his revision jurisdiction u/s.263. - AT
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