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 - bogus purchases - The ITAT found the CIT(A)'s decision to restrict the addition to a percentage of disputed purchases as a reasonable estimation. It was noted that without knowing the parties to whom the diamonds were sold, the onus of proving the genuineness of transactions was not fully discharged by the assessee. The ITAT upheld the CIT(A)'s approach as justified and dismissed the Revenue's appeal and the assessee's cross-objection.
Estimation of income - bogus purchases - The ITAT found the CIT(A)'s decision to restrict the addition to a percentage of disputed purchases as a reasonable estimation. It was noted that without knowing the parties to whom the diamonds were sold, the onus of proving the genuineness of transactions was not fully discharged by the assessee. The ITAT upheld the CIT(A)'s approach as justified and dismissed the Revenue's appeal and the assessee's cross-objection.
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