Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
Battery-integrated tablet rear covers classify as lithium-ion accumulators when protective components enable the battery's active energy-storage funct...
Penalty under section 271AAC(1) was not sustainable where unexplained cash deposits were assessed only by estimating and restricting the addition to a profit percentage. An ad hoc estimated addition did not, by itself, establish conscious concealment or undisclosed income. The penalty levied solely on that estimated addition was therefore deleted, and the appeal was allowed.
Penalty under section 271AAC(1) was not sustainable where unexplained cash deposits were assessed only by estimating and restricting the addition to a profit percentage. An ad hoc estimated addition did not, by itself, establish conscious concealment or undisclosed income. The penalty levied solely on that estimated addition was therefore deleted, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
