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...
Validity of Revision u/s 263 - Admisibility of Deduction u/s 80P, Deduction from total income under chapter VI-A and business expenses - The ITAT quashed the order passed under section 263 of the Income Tax Act by the PCIT, essentially allowing the appeal in favor of the assessee. The Tribunal concluded that the AO had made the necessary inquiries and verifications, and therefore, the PCIT's revision under section 263 was not warranted.
Validity of Revision u/s 263 - Admisibility of Deduction u/s 80P, Deduction from total income under chapter VI-A and business expenses - The ITAT quashed the order passed under section 263 of the Income Tax Act by the PCIT, essentially allowing the appeal in favor of the assessee. The Tribunal concluded that the AO had made the necessary inquiries and verifications, and therefore, the PCIT's revision under section 263 was not warranted.
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