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 - PCIT observed that AO had failed to examine and verify the issues related to share premium received and interest earned, which issues had remained unaddressed - The action of the Ld. PCIT is in direct contravention of the provisions of Explanation (a)(i) to section 56(2)(vii) of the I.T. Act read with rule 11UA(2)(b) of the I.T. Rules. - AO could not have changed the method of valuation opted by the Assessee - Revision order quashed - AT
Revision u/s 263 - PCIT observed that AO had failed to examine and verify the issues related to share premium received and interest earned, which issues had remained unaddressed - The action of the Ld. PCIT is in direct contravention of the provisions of Explanation (a)(i) to section 56(2)(vii) of the I.T. Act read with rule 11UA(2)(b) of the I.T. Rules. - AO could not have changed the method of valuation opted by the Assessee - Revision order quashed - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
