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...
Independent corroboration and a direct nexus with the assessee are presented as essential before search statements, loose papers or third-party records can support additions. The material discusses acceptance of documented consultancy expenditure where agreements, invoices, banking payments and tax deduction support services, while retracted statements and uncorroborated papers do not establish non-genuine expenditure. It also addresses alleged unaccounted sales, cash salaries, land on-money, unexplained money, and liaisoning or gift expenditure. For unexplained expenditure, actual incurrence must be proved before examining its source; estimates, ambiguous loose sheets, and uninvestigated retractions are insufficient. Third-party parallel records or off-portal order communications require evidence of unrecorded supply, cash receipt, dispatch, stock discrepancy, or other linkage to the assessee.
Independent corroboration and a direct nexus with the assessee are presented as essential before search statements, loose papers or third-party records can support additions. The material discusses acceptance of documented consultancy expenditure where agreements, invoices, banking payments and tax deduction support services, while retracted statements and uncorroborated papers do not establish non-genuine expenditure. It also addresses alleged unaccounted sales, cash salaries, land on-money, unexplained money, and liaisoning or gift expenditure. For unexplained expenditure, actual incurrence must be proved before examining its source; estimates, ambiguous loose sheets, and uninvestigated retractions are insufficient. Third-party parallel records or off-portal order communications require evidence of unrecorded supply, cash receipt, dispatch, stock discrepancy, or other linkage to the assessee.
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