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...
Documented listed-share transactions cannot be treated as non-genuine merely because they yielded extraordinary profits, involved a penny stock, or reflected adverse company indicators. In the absence of evidence linking the taxpayer to price rigging, entry operators or other manipulation, the alleged capital-gains addition and consequential commission expenditure were deleted. Unsecured loans were accepted as explained based on lenders' tax returns, confirmations, bank statements and a corporate lender's affidavit. A life-insurance premium deduction was also allowed because the record showed adjustment in the relevant financial year, despite the receipt's later assessment-year reference.
Documented listed-share transactions cannot be treated as non-genuine merely because they yielded extraordinary profits, involved a penny stock, or reflected adverse company indicators. In the absence of evidence linking the taxpayer to price rigging, entry operators or other manipulation, the alleged capital-gains addition and consequential commission expenditure were deleted. Unsecured loans were accepted as explained based on lenders' tax returns, confirmations, bank statements and a corporate lender's affidavit. A life-insurance premium deduction was also allowed because the record showed adjustment in the relevant financial year, despite the receipt's later assessment-year reference.
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