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 - addition u/s. 68 r.w.s. 115BBE - Assessee has submitted before the AO that the repayment of unsecured loan was made from sell proceeds - the Tribunal was right in holding that it was not a case where there was lack of inquiry and therefore there was no ground on which revisionary powers under Section 263 could have been invoked - HC
Revision u/s 263 - addition u/s. 68 r.w.s. 115BBE - Assessee has submitted before the AO that the repayment of unsecured loan was made from sell proceeds - the Tribunal was right in holding that it was not a case where there was lack of inquiry and therefore there was no ground on which revisionary powers under Section 263 could have been invoked - HC
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