Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Suppressed turnover arising from unrecorded sales generated in a disclosed business is assessable only to the embedded profit, absent evidence of unexplained investment or an independent undisclosed activity. Because gross receipts recover both cost and profit, historical profitability provides an objective estimation basis; a moderately higher margin may apply to incremental out-of-books realisation. Profit was estimated at 2%, restricting the turnover addition to that amount; the evidentiary value of individual Excel sheets remained undecided. Cash-payment disallowance requires payment-wise, person-wise and day-wise verification against the prescribed limit, rather than yearly ledger aggregates. Claimed Rule 6DD exceptions require supporting-material verification, and the disallowance was remanded for that limited examination.
Suppressed turnover arising from unrecorded sales generated in a disclosed business is assessable only to the embedded profit, absent evidence of unexplained investment or an independent undisclosed activity. Because gross receipts recover both cost and profit, historical profitability provides an objective estimation basis; a moderately higher margin may apply to incremental out-of-books realisation. Profit was estimated at 2%, restricting the turnover addition to that amount; the evidentiary value of individual Excel sheets remained undecided. Cash-payment disallowance requires payment-wise, person-wise and day-wise verification against the prescribed limit, rather than yearly ledger aggregates. Claimed Rule 6DD exceptions require supporting-material verification, and the disallowance was remanded for that limited examination.
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