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 - valuation of the cost of construction for hospital building - as per explanation u/s 263, the AO did not discharge his liability fully. First the AO is an investigating officer thereafter he is an adjudicating officer. Considering the entire facts on the order passed by the AO, which is erroneous and prejudicial to the interest of the revenue, we uphold the action of the ld. Pr.CIT - AT
Revision u/s 263 - valuation of the cost of construction for hospital building - as per explanation u/s 263, the AO did not discharge his liability fully. First the AO is an investigating officer thereafter he is an adjudicating officer. Considering the entire facts on the order passed by the AO, which is erroneous and prejudicial to the interest of the revenue, we uphold the action of the ld. Pr.CIT - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
