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...
Clandestine removal - it is alleged that respondents have shown excess manufacture in order to avail excess refund to the tune of Rs. 60 lakhs - burden of proof lies with the prosecution or not - The Tribunal acknowledges the serious nature of the charge but finds that the Revenue failed to establish tangible evidence beyond a single test run. They emphasize the necessity of thorough investigation and tangible evidence to prove such allegations conclusively. - The Tribunal notes the various factors affecting fuel consumption and production, concluding that a single test run cannot accurately represent overall production.
Clandestine removal - it is alleged that respondents have shown excess manufacture in order to avail excess refund to the tune of Rs. 60 lakhs - burden of proof lies with the prosecution or not - The Tribunal acknowledges the serious nature of the charge but finds that the Revenue failed to establish tangible evidence beyond a single test run. They emphasize the necessity of thorough investigation and tangible evidence to prove such allegations conclusively. - The Tribunal notes the various factors affecting fuel consumption and production, concluding that a single test run cannot accurately represent overall production.
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