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 - onus to prove - The Pr. CIT found the assessment order erroneous and prejudicial to the revenue's interests due to inadequate verification. - The Tribunal upheld the Ld. Principal Commissioner's decision, stating that the AO had not adequately examined the sources of cash deposits nor obtained relevant details or evidence before accepting explanations. The appellant failed to provide documentary evidence supporting claims, and the AO's assessment lacked thorough inquiry.
Revision u/s 263 - unexplained cash deposits - onus to prove - The Pr. CIT found the assessment order erroneous and prejudicial to the revenue's interests due to inadequate verification. - The Tribunal upheld the Ld. Principal Commissioner's decision, stating that the AO had not adequately examined the sources of cash deposits nor obtained relevant details or evidence before accepting explanations. The appellant failed to provide documentary evidence supporting claims, and the AO's assessment lacked thorough inquiry.
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