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...
Rejection of liquor-trade book results is justified where proper books, stock registers, sale bills and supporting vouchers are not maintained, and declared profit is materially below comparable industry margins. Profit from liquor trading may then be estimated at 3% of stock put to use. Advertisement-display receipts earned for permitting liquor-product displays in business premises constitute business receipts and may be separately added where they were excluded from turnover used for profit estimation. The rejection of books, profit estimation and separate addition of advertisement-display receipts were sustained, and the appeal was dismissed.
Rejection of liquor-trade book results is justified where proper books, stock registers, sale bills and supporting vouchers are not maintained, and declared profit is materially below comparable industry margins. Profit from liquor trading may then be estimated at 3% of stock put to use. Advertisement-display receipts earned for permitting liquor-product displays in business premises constitute business receipts and may be separately added where they were excluded from turnover used for profit estimation. The rejection of books, profit estimation and separate addition of advertisement-display receipts were sustained, and the appeal was dismissed.
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