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 - Assessee has failed to establish that the AO has made necessary enquiries - there is no doubt about applicability of Explanation (2) to section 263(1) of the IT Act, assessment year being 2017-18 the assessment order as well as the impugned revisionary order having been passed after aforesaid date of 01/06/2015. - Revision order sustained - AT
Revision u/s 263 - Assessee has failed to establish that the AO has made necessary enquiries - there is no doubt about applicability of Explanation (2) to section 263(1) of the IT Act, assessment year being 2017-18 the assessment order as well as the impugned revisionary order having been passed after aforesaid date of 01/06/2015. - Revision order sustained - AT
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