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...
Addition made towards excess physical stock during the survey - unexplained investment u/s 69 taxable at rates prescribed u/s 115BBE - The ITAT concurred with the Commissioner's decision, stating that the Assessing Officer failed to rebut the assessee's valuation adjustments adequately. They agreed that the discrepancy in stock could be attributed to unrecorded sales, and upheld the Commissioner's decision to treat the addition as business income. - The ITAT dismissed the Revenue's appeal, affirming the Commissioner's order deleting the additions.
Addition made towards excess physical stock during the survey - unexplained investment u/s 69 taxable at rates prescribed u/s 115BBE - The ITAT concurred with the Commissioner's decision, stating that the Assessing Officer failed to rebut the assessee's valuation adjustments adequately. They agreed that the discrepancy in stock could be attributed to unrecorded sales, and upheld the Commissioner's decision to treat the addition as business income. - The ITAT dismissed the Revenue's appeal, affirming the Commissioner's order deleting the additions.
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