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...
Telescoping of cash recognised in an earlier year as exempt agricultural-land sale proceeds remains available against a later unexplained-money addition unless the Revenue establishes its intervening investment or expenditure. Cash attributed to a non-earning senior citizen mother and minor children may be explained through household savings, pin money, stridhan and customary family gifts; non-filing of returns alone does not discredit such explanations where income does not exceed the non-taxable threshold. The evaluation must account for human probabilities, surrounding circumstances and Indian socio-cultural practices rather than demand commercial records or mathematical precision. The remaining addition for unexplained money was deleted.
Telescoping of cash recognised in an earlier year as exempt agricultural-land sale proceeds remains available against a later unexplained-money addition unless the Revenue establishes its intervening investment or expenditure. Cash attributed to a non-earning senior citizen mother and minor children may be explained through household savings, pin money, stridhan and customary family gifts; non-filing of returns alone does not discredit such explanations where income does not exceed the non-taxable threshold. The evaluation must account for human probabilities, surrounding circumstances and Indian socio-cultural practices rather than demand commercial records or mathematical precision. The remaining addition for unexplained money was deleted.
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