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...
ITAT dismissed the assessee's challenge to the transfer of jurisdiction u/s 127, holding that participation in assessment without timely objection u/s 124(3) precluded such plea. ITAT upheld the estimation of gross profit at 35% for AYs 2005-06 and 2006-07 as reasonable, based on the assessee's own past results and telescoping already granted. For AY 2007-08, ITAT rejected further GP addition, holding no basis for enhancement post-search. Additions towards alleged unaccounted initial investment in stock, unexplained investment in immovable property, unaccounted stock (gold and major part of silver), unexplained cash/advances u/ss 69A/69C, loose papers (including "Roop Sangam"), and gold transactions with a third party were all deleted for lack of corroborative evidence and to avoid double taxation. Overall, Revenue's multiple additions were largely disallowed, save for sustained GP estimation for specified years.
ITAT dismissed the assessee's challenge to the transfer of jurisdiction u/s 127, holding that participation in assessment without timely objection u/s 124(3) precluded such plea. ITAT upheld the estimation of gross profit at 35% for AYs 2005-06 and 2006-07 as reasonable, based on the assessee's own past results and telescoping already granted. For AY 2007-08, ITAT rejected further GP addition, holding no basis for enhancement post-search. Additions towards alleged unaccounted initial investment in stock, unexplained investment in immovable property, unaccounted stock (gold and major part of silver), unexplained cash/advances u/ss 69A/69C, loose papers (including "Roop Sangam"), and gold transactions with a third party were all deleted for lack of corroborative evidence and to avoid double taxation. Overall, Revenue's multiple additions were largely disallowed, save for sustained GP estimation for specified years.
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