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...
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
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