Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Estimation of income - alleged commission income on accommodation entry - though Section 145(3) gives discretion to the AO to make an assessment in the manner provided in Section 144, yet this discretion cannot be exercised arbitrarily - there should be any material for the basis adopted by the AO or the Tribunal and the material which is irrelevant or which amounts to mere guesswork or conjecture is no material - addition deleted
Estimation of income - alleged commission income on accommodation entry - though Section 145(3) gives discretion to the AO to make an assessment in the manner provided in Section 144, yet this discretion cannot be exercised arbitrarily - there should be any material for the basis adopted by the AO or the Tribunal and the material which is irrelevant or which amounts to mere guesswork or conjecture is no material - addition deleted
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