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...
Unexplained investment in residential property is to be assessed on reliable evidence: an insurance proposal is only an estimate, while the taxpayer's disclosed estimate may be accepted where supported by statements and accounts. Expenditure claimed for old land and building requires evidence and remains unexplained if unproved. Telescoping of undisclosed cash receipts against property investment is unavailable without material showing that both relate to the same period. Unaccounted fixed-deposit additions should be confined to the actual amounts invested, not their maturity values. The discussion describes modification of the property-investment addition, sustenance of the cash-receipts addition, and restriction of the fixed-deposit addition to actual investment.
Unexplained investment in residential property is to be assessed on reliable evidence: an insurance proposal is only an estimate, while the taxpayer's disclosed estimate may be accepted where supported by statements and accounts. Expenditure claimed for old land and building requires evidence and remains unexplained if unproved. Telescoping of undisclosed cash receipts against property investment is unavailable without material showing that both relate to the same period. Unaccounted fixed-deposit additions should be confined to the actual amounts invested, not their maturity values. The discussion describes modification of the property-investment addition, sustenance of the cash-receipts addition, and restriction of the fixed-deposit addition to actual investment.
Note: It is a system-generated summary and is for quick reference only.