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...
RTGS credits claimed as gold-sale proceeds were treated as a benami transaction because the appellant did not prove a prior business relationship with the remitting entities or independently corroborate invoices, purchase bills, ledgers and stock records. The undisputed cash deposit with the alleged benamidar, subsequent RTGS transfers, timing after demonetisation and bank records supported confirmation of the provisional attachment. Denial of cross-examination did not breach natural justice: no intermediary statement existed, the alleged benamidar had been made available but did not appear, and no actual prejudice was shown. The appeal was dismissed.
RTGS credits claimed as gold-sale proceeds were treated as a benami transaction because the appellant did not prove a prior business relationship with the remitting entities or independently corroborate invoices, purchase bills, ledgers and stock records. The undisputed cash deposit with the alleged benamidar, subsequent RTGS transfers, timing after demonetisation and bank records supported confirmation of the provisional attachment. Denial of cross-examination did not breach natural justice: no intermediary statement existed, the alleged benamidar had been made available but did not appear, and no actual prejudice was shown. The appeal was dismissed.
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