Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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