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...
CIT(E) exercised revisionary powers under s.263 due to AO's failure to investigate payments for machinery supplied through an employee. Despite receiving specific information, AO made no inquiries regarding a notarized tripartite MoU involving M/s. Aarti Enterprises and Dr. M.S. Hiremath, making the assessment order erroneous and prejudicial to revenue interests. ITAT rejected assessee's contention that tax exemptions under ss.12AA and 10(23C)(via) nullified revenue prejudice, holding that potential impact could only be determined after proper examination. The tribunal upheld CIT(E)'s jurisdiction under s.263, finding sufficient grounds for revision, and dismissed assessee's appeal.
CIT(E) exercised revisionary powers under s.263 due to AO's failure to investigate payments for machinery supplied through an employee. Despite receiving specific information, AO made no inquiries regarding a notarized tripartite MoU involving M/s. Aarti Enterprises and Dr. M.S. Hiremath, making the assessment order erroneous and prejudicial to revenue interests. ITAT rejected assessee's contention that tax exemptions under ss.12AA and 10(23C)(via) nullified revenue prejudice, holding that potential impact could only be determined after proper examination. The tribunal upheld CIT(E)'s jurisdiction under s.263, finding sufficient grounds for revision, and dismissed assessee's appeal.
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