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...
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
Undisclosed mutual fund and insurance investments were not treated as wholly unexplained because the assessee had produced balance sheet, capital account, investment statements and supporting land and crop-sale records, although some material remained self-serving and inconsistent. The Tribunal applied the principle that the Act taxes income, not gross receipts, and therefore rejected assessment of the entire investment as deemed income under section 115BBE. It restricted the addition to 5% of the impugned investment figure and directed taxation under the normal provisions instead of deemed-income taxation.
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