Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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 - AO has not verified the cash deposited by the partners and also loan taken from the Trust and cash embezzlement and interest free advances to related persons. All these things are not been examined by the AO. DR has rightly pointed out that ld. Pr. CIT has rightly exercised his revisionary powers u/s 263 of the Act - AT
Revision u/s 263 by CIT - AO has not verified the cash deposited by the partners and also loan taken from the Trust and cash embezzlement and interest free advances to related persons. All these things are not been examined by the AO. DR has rightly pointed out that ld. Pr. CIT has rightly exercised his revisionary powers u/s 263 of the Act - AT
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