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 based on retracted statement recorded on oath u/s 132(4)/133A - Statement taken even u/s 132(4) of the Act cannot be used as conclusive evidence if it is not backed by credible evidence - AO not having any fresh information/material in his possession, merely on retracted statement formed his belief about escapement of income which is not sustainable in law. - AT
Addition based on retracted statement recorded on oath u/s 132(4)/133A - Statement taken even u/s 132(4) of the Act cannot be used as conclusive evidence if it is not backed by credible evidence - AO not having any fresh information/material in his possession, merely on retracted statement formed his belief about escapement of income which is not sustainable in law. - AT
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