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 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
Validity of Revision u/s 263 - The tribunal held that the exercise of the second revision jurisdiction by the PCIT on the same issue was not justified. It noted that the AO had made necessary inquiries as per the directions of the first PCIT and that the assessee had provided sufficient evidence to prove the identity, creditworthiness, and genuineness of the share subscribers.
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