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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Documentary evidence supporting purchases, including invoices, e-way bills, bank records, KYC documents, transporter details, receipts, photographs and GST returns, was accepted as unrebutted because no discrepancy or fabrication was shown. The Tribunal held that mere suspicion that such material could be manufactured was insufficient, and that alleged bogus purchases and grey-market purchases must be tested on different parameters. Where documentary proof is produced, it can be displaced only by independent enquiry or material showing lower-price availability and inflation of bills. In the absence of such rebuttal, the estimated profit addition for alleged non-genuine purchases was unsustainable and deleted.
Documentary evidence supporting purchases, including invoices, e-way bills, bank records, KYC documents, transporter details, receipts, photographs and GST returns, was accepted as unrebutted because no discrepancy or fabrication was shown. The Tribunal held that mere suspicion that such material could be manufactured was insufficient, and that alleged bogus purchases and grey-market purchases must be tested on different parameters. Where documentary proof is produced, it can be displaced only by independent enquiry or material showing lower-price availability and inflation of bills. In the absence of such rebuttal, the estimated profit addition for alleged non-genuine purchases was unsustainable and deleted.
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