Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
TP Adjustment - Interest on delayed receivables - only two instances where there has been a marginal delay of 60 days and 26 days. Considering the nominal delay in the realization period and the overall average realization period being well before the grace period - there is no requirement to charge any interest towards receivables and, therefore, the TP adjustment made in this regard should be deleted - AT
TP Adjustment - Interest on delayed receivables - only two instances where there has been a marginal delay of 60 days and 26 days. Considering the nominal delay in the realization period and the overall average realization period being well before the grace period - there is no requirement to charge any interest towards receivables and, therefore, the TP adjustment made in this regard should be deleted - AT
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