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Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
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Section 263 confers broad revisional power to examine an...
Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability confirmed.
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Section 263 confers broad revisional power to examine an assessment order and direct fresh assessment, modification or cancellation when the order is erroneous and prejudicial to Revenue; that power applies equally to a block assessment under section 158BC read with section 143(3), so the revision was upheld. Applying ACIT v. A.R. Enterprises, advance tax payment or a belated return filed after search does not convert undisclosed income into disclosed income, and the AY 2002-2003 amount was correctly treated as undisclosed income. The deletion of addition for suppression of freight charges was set aside as the contrary assumption about matching expenditure was untenable, while the lorry hire provision was treated as accrued liability under mercantile accounting and the deletion on that issue was sustained. The remand on token booking receipts was left undisturbed.
Section 263 confers broad revisional power to examine an assessment order and direct fresh assessment, modification or cancellation when the order is erroneous and prejudicial to Revenue; that power applies equally to a block assessment under section 158BC read with section 143(3), so the revision was upheld. Applying ACIT v. A.R. Enterprises, advance tax payment or a belated return filed after search does not convert undisclosed income into disclosed income, and the AY 2002-2003 amount was correctly treated as undisclosed income. The deletion of addition for suppression of freight charges was set aside as the contrary assumption about matching expenditure was untenable, while the lorry hire provision was treated as accrued liability under mercantile accounting and the deletion on that issue was sustained. The remand on token booking receipts was left undisturbed.
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