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 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
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