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...
Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.
Reassessment based on search-related information may be initiated under reassessment provisions where the Assessing Officer also relies on independent enquiries into transactions with an alleged entry provider, rather than on search material alone. Approval for the reassessment notice was treated as procedurally valid and non-mechanical, and the challenge to reassessment failed. Where sales are accepted but purchases from an alleged accommodation-entry provider remain unverifiable, the entire purchase amount need not be disallowed, particularly where the relied-on statement was retracted. The addition was confined to the profit element reflected in the taxpayer's gross-profit position, fixed at 6% of the disputed purchases. The appeal was partly allowed on the quantum of addition.
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