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 - Capital gain computation - the out of 100 % sales consideration 95.36 % is offered as capital gain and the claim of the assessee is less than 5 % of the total consideration in this case, thus, what more AO can find fault when he has already disallowed the cost which in his opinion is not supported and thus AO has already verified the issues which the PCIT is pointing out - Order of AO restored - AT
Revision u/s 263 by CIT - Capital gain computation - the out of 100 % sales consideration 95.36 % is offered as capital gain and the claim of the assessee is less than 5 % of the total consideration in this case, thus, what more AO can find fault when he has already disallowed the cost which in his opinion is not supported and thus AO has already verified the issues which the PCIT is pointing out - Order of AO restored - AT
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