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...
For a kachha arhtia, tax-audit turnover comprises only commission earned and excludes sale proceeds of goods belonging to principals. Where the accepted commission income remains below the prescribed limit, no tax-audit obligation arises. The notes also state that a penalty for failure to obtain audit cannot apply where the Revenue's position is that no books of account were maintained, because audit presupposes existing books. On the separate obligation to maintain books, the statutory conditions under section 44AA must be examined with reference to the preceding three previous years after allowing the taxpayer to explain the relevant facts. The books-maintenance penalty was remanded for fresh examination, while the tax-audit penalty was deleted.
For a kachha arhtia, tax-audit turnover comprises only commission earned and excludes sale proceeds of goods belonging to principals. Where the accepted commission income remains below the prescribed limit, no tax-audit obligation arises. The notes also state that a penalty for failure to obtain audit cannot apply where the Revenue's position is that no books of account were maintained, because audit presupposes existing books. On the separate obligation to maintain books, the statutory conditions under section 44AA must be examined with reference to the preceding three previous years after allowing the taxpayer to explain the relevant facts. The books-maintenance penalty was remanded for fresh examination, while the tax-audit penalty was deleted.
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