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...
Rationalisation of Appeals to the Appellate Tribunal - as per the amendment to sec 253 revisional order passed u/s 263 by PCC or CC or an order u/s 154 are now appealable to Appellate Tribunal. Also, Memorandum of cross objection has been introduced for the revenue where in case respondent files appeal against the order of Commissioner (Appeals), like Principal Commissioner or Commissioner or Principal Director or Director etc. AO would be able to file a cross objection to such appeal which cannot be filed presently.
Rationalisation of Appeals to the Appellate Tribunal - as per the amendment to sec 253 revisional order passed u/s 263 by PCC or CC or an order u/s 154 are now appealable to Appellate Tribunal. Also, Memorandum of cross objection has been introduced for the revenue where in case respondent files appeal against the order of Commissioner (Appeals), like Principal Commissioner or Commissioner or Principal Director or Director etc. AO would be able to file a cross objection to such appeal which cannot be filed presently.
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