Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Addressing disputed purchases and commission claims, the note holds that where sales and business are accepted, purchases cannot be treated as wholly non-existent and an addition should be limited to the profit element; accordingly purchases from two suppliers (where statutory notices were unserved) were estimated at the declared gross profit rate of 6.5% to account for possible embedded profit and price inflation. Separately, commission and brokerage payments were held allowable where primary documentary evidence (ledgers, bills, bank payments, TDS proof) was produced and no independent adverse material or enquiries proved the payments were sham, so full disallowance was not justified.
Addressing disputed purchases and commission claims, the note holds that where sales and business are accepted, purchases cannot be treated as wholly non-existent and an addition should be limited to the profit element; accordingly purchases from two suppliers (where statutory notices were unserved) were estimated at the declared gross profit rate of 6.5% to account for possible embedded profit and price inflation. Separately, commission and brokerage payments were held allowable where primary documentary evidence (ledgers, bills, bank payments, TDS proof) was produced and no independent adverse material or enquiries proved the payments were sham, so full disallowance was not justified.
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