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 - Capital gain computation - To us, it is a clear case of valuation being made by applying reverse indexation, i.e., by arriving at the value of land as on 01/04/1981, upon first determining the amount of capital gain that is to be disclosed. This is apparent from his order being sans any finding qua such basis, which also forms the reason for reassessment and, rather, without any deliberation thereon. - AT
Revision u/s 263 - Capital gain computation - To us, it is a clear case of valuation being made by applying reverse indexation, i.e., by arriving at the value of land as on 01/04/1981, upon first determining the amount of capital gain that is to be disclosed. This is apparent from his order being sans any finding qua such basis, which also forms the reason for reassessment and, rather, without any deliberation thereon. - AT
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