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...
Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.
Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.
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