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...
AO failed to conduct proper inquiries regarding genuineness of loan transactions for property acquisition. Bank statements revealed assessee lacked funds, payments made through loans from two parties. AO accepted evidence without verification, neglecting examination of interest payment, TDS deduction on loans. AO's lack of inquiry rendered order erroneous, prejudicial to revenue interests, justifying CIT's revision u/s 263. Non-application of mind, incorrect assumptions or law application by AO makes order erroneous, prejudicial, validating CIT's revisionary jurisdiction u/s 263. Decided against assessee.
AO failed to conduct proper inquiries regarding genuineness of loan transactions for property acquisition. Bank statements revealed assessee lacked funds, payments made through loans from two parties. AO accepted evidence without verification, neglecting examination of interest payment, TDS deduction on loans. AO's lack of inquiry rendered order erroneous, prejudicial to revenue interests, justifying CIT's revision u/s 263. Non-application of mind, incorrect assumptions or law application by AO makes order erroneous, prejudicial, validating CIT's revisionary jurisdiction u/s 263. Decided against assessee.
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