Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Trade and quantity discounts received by a milk resale agent constituted an explained source of income where bank statements showed that sale proceeds were deposited into a joint account with the dairy and withdrawn by the dairy on the same day. Treating those discounts as unexplained money was therefore unwarranted. Profit estimation at 70% of the total discounts, with only 30% allowed for storage and distribution expenses, lacked a proper basis. The addition relating to the discounts was deleted.
Trade and quantity discounts received by a milk resale agent constituted an explained source of income where bank statements showed that sale proceeds were deposited into a joint account with the dairy and withdrawn by the dairy on the same day. Treating those discounts as unexplained money was therefore unwarranted. Profit estimation at 70% of the total discounts, with only 30% allowed for storage and distribution expenses, lacked a proper basis. The addition relating to the discounts was deleted.
Note: It is a system-generated summary and is for quick reference only.