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...
Revision under section 263 failed because CSR expenditure cannot be added to book profit under section 115JB except through the specific adjustments in the Explanation, and the Assessing Officer had no power to alter the audited accounts beyond those statutory items. The Tribunal also held that a section 14A read with Rule 8D disallowance cannot be imported into MAT book profit when tax liability is determined under section 115JB, so the omission to examine that issue caused no prejudice to the Revenue. As neither ground made the assessment order both erroneous and prejudicial, the revisionary order was quashed.
Revision under section 263 failed because CSR expenditure cannot be added to book profit under section 115JB except through the specific adjustments in the Explanation, and the Assessing Officer had no power to alter the audited accounts beyond those statutory items. The Tribunal also held that a section 14A read with Rule 8D disallowance cannot be imported into MAT book profit when tax liability is determined under section 115JB, so the omission to examine that issue caused no prejudice to the Revenue. As neither ground made the assessment order both erroneous and prejudicial, the revisionary order was quashed.
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