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...
Material seized from a company director who managed its day-to-day affairs and was searched simultaneously could be used for the company's assessment under section 153A; separate proceedings under section 153C were unnecessary. The Tribunal found the consolidated section 153D approval for four assessment years mechanical because it showed no year-wise application of mind, quashing the assessments. For unabated years, the consistently accepted Project Completion Method could not be replaced by the Percentage Completion Method without relevant seized material, rejection of accounts under section 145(3), or a cogent factual basis; the resulting additions were deleted. Additions for both receipts and payments reflected in the same seized papers were also deleted as double taxation of income already offered and accepted.
Material seized from a company director who managed its day-to-day affairs and was searched simultaneously could be used for the company's assessment under section 153A; separate proceedings under section 153C were unnecessary. The Tribunal found the consolidated section 153D approval for four assessment years mechanical because it showed no year-wise application of mind, quashing the assessments. For unabated years, the consistently accepted Project Completion Method could not be replaced by the Percentage Completion Method without relevant seized material, rejection of accounts under section 145(3), or a cogent factual basis; the resulting additions were deleted. Additions for both receipts and payments reflected in the same seized papers were also deleted as double taxation of income already offered and accepted.
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