Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
In the ITAT Jaipur case, the issue revolved around a revision u/s 263 by CIT concerning the assessee's case under limited scrutiny u/s 143(3). The primary focus was on payments to specified persons and a percentage disallowance on salary payments. The tribunal held that the AO had conducted inquiries and verified details submitted by the assessee, allowing the salary payments. The observations by the PCIT were based on a different assessment year, and a disallowance in one year cannot be the basis for doubting claims in another year. The tribunal concluded that the revision proceedings by the PCIT were beyond jurisdiction and against legal principles, quashing the order u/s 263 and allowing the assessee's appeal.
In the ITAT Jaipur case, the issue revolved around a revision u/s 263 by CIT concerning the assessee's case under limited scrutiny u/s 143(3). The primary focus was on payments to specified persons and a percentage disallowance on salary payments. The tribunal held that the AO had conducted inquiries and verified details submitted by the assessee, allowing the salary payments. The observations by the PCIT were based on a different assessment year, and a disallowance in one year cannot be the basis for doubting claims in another year. The tribunal concluded that the revision proceedings by the PCIT were beyond jurisdiction and against legal principles, quashing the order u/s 263 and allowing the assessee's appeal.
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