Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Restricted gold import conditions: breach permits absolute confiscation, while redemption remains discretionary and is rarely disturbed on writ review...
Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.
Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.
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