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 Tribunal addressed various issues, including the validity of the reopening of assessment, the genuineness of purchases, calculation of the profit element, and determination of the gross profit rate. It found that the purchases were reconciled with sales, indicating their genuineness. Relying on judicial precedents, the Tribunal concluded that only the profit element of the alleged bogus purchases should be assessed. It accepted the industry-standard gross profit rate of 3% for diamond trading and modified the CIT(A)'s order accordingly, restricting the addition to the profit element.
Estimation of income - bogus purchases - The Tribunal addressed various issues, including the validity of the reopening of assessment, the genuineness of purchases, calculation of the profit element, and determination of the gross profit rate. It found that the purchases were reconciled with sales, indicating their genuineness. Relying on judicial precedents, the Tribunal concluded that only the profit element of the alleged bogus purchases should be assessed. It accepted the industry-standard gross profit rate of 3% for diamond trading and modified the CIT(A)'s order accordingly, restricting the addition to the profit element.
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