Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
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...
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CIT(A) determined profit at 5.47% on total purchases. Assessee produced sufficient evidence regarding purchases, movement of goods, GST payment on transportation, expenses accounted for. No evidence of routing back payments. CIT(A) endorsed assessee's contentions but erred in directing gross profit rate application, defying logic. Assessee discharged onus, furnished abundant evidence substantiating purchases' genuineness. CIT(A) erred in sustaining gross profit addition on alleged purchases over declared profit. Gross profit determined by CIT(A) directed to be deleted. Addition u/s 56(2)(x) for difference between purchase price and stamp duty value of property purchased, without referring valuation to DVO, is unsustainable and liable to be deleted. AO bound to refer valuation to DVO when assessee disputes stamp duty value. Addition by AO and confirmation by CIT(A), without DVO reference, unsustainable and deleted in assessee's favor.
CIT(A) determined profit at 5.47% on total purchases. Assessee produced sufficient evidence regarding purchases, movement of goods, GST payment on transportation, expenses accounted for. No evidence of routing back payments. CIT(A) endorsed assessee's contentions but erred in directing gross profit rate application, defying logic. Assessee discharged onus, furnished abundant evidence substantiating purchases' genuineness. CIT(A) erred in sustaining gross profit addition on alleged purchases over declared profit. Gross profit determined by CIT(A) directed to be deleted. Addition u/s 56(2)(x) for difference between purchase price and stamp duty value of property purchased, without referring valuation to DVO, is unsustainable and liable to be deleted. AO bound to refer valuation to DVO when assessee disputes stamp duty value. Addition by AO and confirmation by CIT(A), without DVO reference, unsustainable and deleted in assessee's favor.
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