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 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
Revision u/s 263 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
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