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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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Excess stock found during survey in assessee's business premises led to surrendered income. Assessing Officer accepted return figures but applied higher tax rate u/s 115BBE, citing lack of stock register maintenance. Following precedents, it was held that surrendered income from excess stock during survey cannot be taxed u/s 69 deeming provisions. It should be assessed as business income at normal rates. Section 115BBE is inapplicable. Assessee's appeal allowed, and income to be charged at regular tax rates.
Excess stock found during survey in assessee's business premises led to surrendered income. Assessing Officer accepted return figures but applied higher tax rate u/s 115BBE, citing lack of stock register maintenance. Following precedents, it was held that surrendered income from excess stock during survey cannot be taxed u/s 69 deeming provisions. It should be assessed as business income at normal rates. Section 115BBE is inapplicable. Assessee's appeal allowed, and income to be charged at regular tax rates.
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