Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. - AT
Revision u/s 263 - selection of the case under limited scrutiny - expansion scope of limited scrutiny - As per CIT high sea sales is speculative transaction and therefore disallowance of loss arising therefrom against the non speculative business income - AO cannot go beyond reasons for of limited scrutiny and thus, it would not be open to the PCIT to pass revisionary order u/s 263 on other aspects and remit matter to AO for fresh assessment. - AT
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