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 allowed the assessee's appeal against the invocation of Section 263 by the Principal Commissioner of Income Tax (PCIT) for disallowing the entire purchases of Rs. 102,43,73,377/-. The Tribunal held that the Assessing Officer (AO) had reasonably disallowed only 10% of the purchases after duly considering the details furnished by the assessee during the assessment proceedings u/s 143(3). The PCIT's action of proposing to disallow the entire purchases against the basic principle of business, without appreciating that the assessee had achieved a turnover of Rs. 132,12,33,622/-, was erroneous. The Tribunal ruled that the AO's order cannot be termed erroneous to invoke Section 263, as it is not every error that should induce the PCIT to exercise powers under that section, especially when the AO has considered the issue carefully and cautiously.
The Appellate Tribunal allowed the assessee's appeal against the invocation of Section 263 by the Principal Commissioner of Income Tax (PCIT) for disallowing the entire purchases of Rs. 102,43,73,377/-. The Tribunal held that the Assessing Officer (AO) had reasonably disallowed only 10% of the purchases after duly considering the details furnished by the assessee during the assessment proceedings u/s 143(3). The PCIT's action of proposing to disallow the entire purchases against the basic principle of business, without appreciating that the assessee had achieved a turnover of Rs. 132,12,33,622/-, was erroneous. The Tribunal ruled that the AO's order cannot be termed erroneous to invoke Section 263, as it is not every error that should induce the PCIT to exercise powers under that section, especially when the AO has considered the issue carefully and cautiously.
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