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...
Addition on account of discrepancy in stock and being estimated value of scrap - the Assessing Officer has not brought out any defects in maintenance of books of accounts and therefore, mere arithmetic calculation made is not suffice for making addition. It is true that the reasons given in impugned order passed by the Tribunal are not happily worded and the order could have been passed using better and accurate language, nonetheless the findings recorded by the ITAT being findings of fact, the appeal cannot be entertained in absence of any substantial question of law being involved in the same. - HC
Addition on account of discrepancy in stock and being estimated value of scrap - the Assessing Officer has not brought out any defects in maintenance of books of accounts and therefore, mere arithmetic calculation made is not suffice for making addition. It is true that the reasons given in impugned order passed by the Tribunal are not happily worded and the order could have been passed using better and accurate language, nonetheless the findings recorded by the ITAT being findings of fact, the appeal cannot be entertained in absence of any substantial question of law being involved in the same. - HC
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