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...
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
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