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...
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
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