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...
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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