Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Gross profit on the declared turnover and resultant undisclosed sales was prescribed at 4.315% after rejection of the flexible-packaging manufacturer's books, using the average rate of eight comparable concerns. In computing undisclosed sales from seized diaries, total sales to traders and verified contra entries were deductible; claimed totaling errors required verification, while post-search sales could not be deducted. No commission addition for alleged RTGS accommodation entries was sustainable because the employee statement lacked corroboration and the relevant trader sales were to be reduced from diary receipts. Verified bank withdrawals supported telescoping of cash found during search against undisclosed-sales income.
Gross profit on the declared turnover and resultant undisclosed sales was prescribed at 4.315% after rejection of the flexible-packaging manufacturer's books, using the average rate of eight comparable concerns. In computing undisclosed sales from seized diaries, total sales to traders and verified contra entries were deductible; claimed totaling errors required verification, while post-search sales could not be deducted. No commission addition for alleged RTGS accommodation entries was sustainable because the employee statement lacked corroboration and the relevant trader sales were to be reduced from diary receipts. Verified bank withdrawals supported telescoping of cash found during search against undisclosed-sales income.
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