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...
The Appellate Tribunal considered a case involving a revision u/s 263 where the Commissioner held that the expenditure claimed by the assessee for payment to sub-contractors was not genuine. The AO had conducted an inquiry and accepted the claim based on relevant material. The work order served as tangible evidence of the agreement between parties. The Commissioner's doubts were based on suspicion, while the AO's decision was reasonable. The AO's inquiry, even if inadequate, did not render the order erroneous. The Commissioner cannot revise based solely on disagreement. The impugned order was set aside as unsustainable. The assessee's appeal was allowed.
The Appellate Tribunal considered a case involving a revision u/s 263 where the Commissioner held that the expenditure claimed by the assessee for payment to sub-contractors was not genuine. The AO had conducted an inquiry and accepted the claim based on relevant material. The work order served as tangible evidence of the agreement between parties. The Commissioner's doubts were based on suspicion, while the AO's decision was reasonable. The AO's inquiry, even if inadequate, did not render the order erroneous. The Commissioner cannot revise based solely on disagreement. The impugned order was set aside as unsustainable. The assessee's appeal was allowed.
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