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...
Bogus purchase bills obtained as accommodation entries warranted addition only to the income component embedded in unverifiable purchases, and the Tribunal was justified in following earlier coordinate Bench decisions on identical facts. The assessee had no actual material purchases, but the addition was restricted to 6% of the impugned purchases in line with prior High Court and Tribunal rulings. The Revenue's challenge to that estimation failed, and the appeal was dismissed.
Bogus purchase bills obtained as accommodation entries warranted addition only to the income component embedded in unverifiable purchases, and the Tribunal was justified in following earlier coordinate Bench decisions on identical facts. The assessee had no actual material purchases, but the addition was restricted to 6% of the impugned purchases in line with prior High Court and Tribunal rulings. The Revenue's challenge to that estimation failed, and the appeal was dismissed.
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