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...
Rejection of the books of account of the assessee company u/s. 145(3) - Estimation of income - The ITAT found the rejection of books of accounts by the AO unjustified as there was no evidence of incorrectness or incompleteness. - The AO's reliance on media clippings and reports without concrete proof was deemed insufficient to reject the books. - On the issue of cash deposits during demonetization, the Tribunal noted that the Assessing Officer's presumption of antedating sales and earning super profits lacked substantiation and relied heavily on speculation. - The Tribunal rejected the AO's presumption of a 25% profit margin on sales and found no basis for the addition.
Rejection of the books of account of the assessee company u/s. 145(3) - Estimation of income - The ITAT found the rejection of books of accounts by the AO unjustified as there was no evidence of incorrectness or incompleteness. - The AO's reliance on media clippings and reports without concrete proof was deemed insufficient to reject the books. - On the issue of cash deposits during demonetization, the Tribunal noted that the Assessing Officer's presumption of antedating sales and earning super profits lacked substantiation and relied heavily on speculation. - The Tribunal rejected the AO's presumption of a 25% profit margin on sales and found no basis for the addition.
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