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 - error noted by the CIT that sale of properties by the assessee during the year was not examined by the AO vis-à-vis its stamp duty value for the purpose of invoking section 43CA - The appellant challenges the validity of the PCIT's directions, particularly regarding property transactions and stamp duty valuations under section 43CA. The ITAT ultimately rules in favor of the appellant, finding no error in the AO's assessment order and determining that the PCIT's directions were beyond the scope of revenue authorities' powers. Additionally, it clarifies the limited role of revenue authorities in questioning stamp duty valuations under section 43CA.
Revision u/s 263 - error noted by the CIT that sale of properties by the assessee during the year was not examined by the AO vis-à-vis its stamp duty value for the purpose of invoking section 43CA - The appellant challenges the validity of the PCIT's directions, particularly regarding property transactions and stamp duty valuations under section 43CA. The ITAT ultimately rules in favor of the appellant, finding no error in the AO's assessment order and determining that the PCIT's directions were beyond the scope of revenue authorities' powers. Additionally, it clarifies the limited role of revenue authorities in questioning stamp duty valuations under section 43CA.
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