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 - Claim made by the assessee u/s. 32AC in respect of investment made in the new plant & machinery - In assessee’s case while interpreting the wordings “acquires and installs” in section 32AC, the AO has taken one view in allowing the deduction based on the submissions of the assessee of various judicial pronouncements rendered in the context of 32(1)(iia); whereas the CIT is not in agreement with the view based on the plain reading of section 32AC. - the CIT is not justified in setting aside the order of the AO - AT
Revision u/s 263 by CIT - Claim made by the assessee u/s. 32AC in respect of investment made in the new plant & machinery - In assessee’s case while interpreting the wordings “acquires and installs” in section 32AC, the AO has taken one view in allowing the deduction based on the submissions of the assessee of various judicial pronouncements rendered in the context of 32(1)(iia); whereas the CIT is not in agreement with the view based on the plain reading of section 32AC. - the CIT is not justified in setting aside the order of the AO - AT
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