Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Additions for alleged unaccounted consideration in real-estate transactions require cogent, reliable and transaction-specific evidence of actual cash receipt or payment. Differing internal price references, ERP capabilities, employee statements, WhatsApp communications and an unsupported discount-based estimation cannot establish suppressed sale consideration without purchaser-wise proof, cash records, receipts, money trail or parallel books. Estimation may quantify undisclosed income only after its existence is established. Third-party loose sheets primarily attract statutory presumptions against their possessor; corroboration of recorded cheque payments does not prove an alleged cash component. Denial of cross-examination of the sheet's author is procedurally defective. Registered conveyances, books and banking trails remain effective affirmative evidence unless displaced by cogent material.
Additions for alleged unaccounted consideration in real-estate transactions require cogent, reliable and transaction-specific evidence of actual cash receipt or payment. Differing internal price references, ERP capabilities, employee statements, WhatsApp communications and an unsupported discount-based estimation cannot establish suppressed sale consideration without purchaser-wise proof, cash records, receipts, money trail or parallel books. Estimation may quantify undisclosed income only after its existence is established. Third-party loose sheets primarily attract statutory presumptions against their possessor; corroboration of recorded cheque payments does not prove an alleged cash component. Denial of cross-examination of the sheet's author is procedurally defective. Registered conveyances, books and banking trails remain effective affirmative evidence unless displaced by cogent material.
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