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 - disallowance u/s 14A r.w.r. 8D - the assessee has not incurred any indirect expenses to earn the exempt income and ld. PCIT has not brought any material to show that the assessee has incurred indirect expenses to earn the exempt income. - PCIT has erred in invoking the provisions of Section 263 - AT
Revision u/s 263 - disallowance u/s 14A r.w.r. 8D - the assessee has not incurred any indirect expenses to earn the exempt income and ld. PCIT has not brought any material to show that the assessee has incurred indirect expenses to earn the exempt income. - PCIT has erred in invoking the provisions of Section 263 - AT
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