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...
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
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