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 - As per CIT AO has not called for any details to ascertain the amount and nature of total remittances received by the assessee during the year - various inconsistencies in the approach of learned CIT gives an impression that he himself was not sure about the nature and character of shipping income earned by the assessee. - CIT was not justified in assuming jurisdiction u/s 263 - AT
Revision u/s 263 - As per CIT AO has not called for any details to ascertain the amount and nature of total remittances received by the assessee during the year - various inconsistencies in the approach of learned CIT gives an impression that he himself was not sure about the nature and character of shipping income earned by the assessee. - CIT was not justified in assuming jurisdiction u/s 263 - AT
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