Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
