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 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
Revision u/s 263 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
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