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...
ITAT modified profit margins for undisclosed income in hotel/restaurant and real estate businesses following search and seizure action. For hotel/restaurant operations, tribunal reduced profit margin from 50% to 40% based on historical book profits ranging from 31-47%. For real estate transactions, margin lowered from 17% to 13% considering actual profit ratios. Regarding unsecured loans under Section 68, ITAT reversed CIT(A)'s deletion and upheld AO's additions, citing absence of incriminating materials during search and applying Abhisar Buildwell precedent. Court emphasized that seized materials must be considered in totality, rejecting selective interpretation, and maintained that only real income can be taxed following Godhra Electricity principles.
ITAT modified profit margins for undisclosed income in hotel/restaurant and real estate businesses following search and seizure action. For hotel/restaurant operations, tribunal reduced profit margin from 50% to 40% based on historical book profits ranging from 31-47%. For real estate transactions, margin lowered from 17% to 13% considering actual profit ratios. Regarding unsecured loans under Section 68, ITAT reversed CIT(A)'s deletion and upheld AO's additions, citing absence of incriminating materials during search and applying Abhisar Buildwell precedent. Court emphasized that seized materials must be considered in totality, rejecting selective interpretation, and maintained that only real income can be taxed following Godhra Electricity principles.
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