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...
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
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