Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Excess business stock comprising regularly traded commodities, found at business premises and explained as arising from suppressed business profits, retains the character of undisclosed business income where no material establishes an extraneous source. Mere non-recording of purchases does not justify treating the stock as unexplained investment. The higher tax rate for deemed income applies only after valid invocation of the relevant deeming provision; consequently, the excess stock is taxable under normal provisions. Interest for delayed return filing remains mandatory but must be computed from the statutory due date, actual filing date and verified period of default, after credit for interest already charged or paid.
Excess business stock comprising regularly traded commodities, found at business premises and explained as arising from suppressed business profits, retains the character of undisclosed business income where no material establishes an extraneous source. Mere non-recording of purchases does not justify treating the stock as unexplained investment. The higher tax rate for deemed income applies only after valid invocation of the relevant deeming provision; consequently, the excess stock is taxable under normal provisions. Interest for delayed return filing remains mandatory but must be computed from the statutory due date, actual filing date and verified period of default, after credit for interest already charged or paid.
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