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...
Penalty for failure to obtain a tax audit applies where existing books of account are not audited; it does not apply merely because books were not maintained or produced. Failure to maintain books and failure to obtain an audit are distinct defaults with separate consequences. Where turnover and profit are estimated from bank deposits because no books are available, estimated turnover or bank statements cannot substitute for books of account capable of audit. On these facts, the penalty for non-audit was unsustainable and was deleted.
Penalty for failure to obtain a tax audit applies where existing books of account are not audited; it does not apply merely because books were not maintained or produced. Failure to maintain books and failure to obtain an audit are distinct defaults with separate consequences. Where turnover and profit are estimated from bank deposits because no books are available, estimated turnover or bank statements cannot substitute for books of account capable of audit. On these facts, the penalty for non-audit was unsustainable and was deleted.
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