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...
Disallowance of raw material consumption - rejection of the books of account - The Appellate Tribunal finds that the AO's ad hoc disallowance without specific reasons for rejecting the books of accounts is unjustified. Mere deviation in the percentage of raw material consumption does not warrant such action. The Tribunal refers to precedent to support its decision, emphasizing that when books of accounts are regularly maintained and audited without adverse opinion, they should be considered correct unless proven otherwise by the revenue.
Disallowance of raw material consumption - rejection of the books of account - The Appellate Tribunal finds that the AO's ad hoc disallowance without specific reasons for rejecting the books of accounts is unjustified. Mere deviation in the percentage of raw material consumption does not warrant such action. The Tribunal refers to precedent to support its decision, emphasizing that when books of accounts are regularly maintained and audited without adverse opinion, they should be considered correct unless proven otherwise by the revenue.
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