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 - taxation being anonymous donation received in cash u/s 115BBC - According to the provisions of Section 115BBC, on anonymous donation tax is required to be charged at the rate of 30% subject to certain deductions. The learned CIT did not invoke the provisions of Section 263 of the act for this reason. - The only reason stated by the PCIT is that the learned assessing officer has granted set off deficit of the assessee trust against the anonymous donation. - both these things are different - Revision order is not correct - AT
Revision u/s 263 by CIT - taxation being anonymous donation received in cash u/s 115BBC - According to the provisions of Section 115BBC, on anonymous donation tax is required to be charged at the rate of 30% subject to certain deductions. The learned CIT did not invoke the provisions of Section 263 of the act for this reason. - The only reason stated by the PCIT is that the learned assessing officer has granted set off deficit of the assessee trust against the anonymous donation. - both these things are different - Revision order is not correct - AT
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