Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Reassessment proceedings in search-related group cases were upheld as valid, with initiation and notices sustained following coordinate-bench precedent and applicable procedural provisions. For receipts characterised as unaccounted 'on money', only the profit element is taxable and the appropriate benchmark rate for estimation was fixed at 10%, reducing higher departmental estimates. Unaccounted profit arising on sale of immovable property must be recognised and taxed in the year of actual sale (execution/registration of the sale deed) where risks and rewards transfer; ICDS III was held inapplicable to the assessee. Confirmed estimated unaccounted profit was permitted to be set off (telescoped) against additions for alleged advances/expenses, avoiding double taxation.
Reassessment proceedings in search-related group cases were upheld as valid, with initiation and notices sustained following coordinate-bench precedent and applicable procedural provisions. For receipts characterised as unaccounted 'on money', only the profit element is taxable and the appropriate benchmark rate for estimation was fixed at 10%, reducing higher departmental estimates. Unaccounted profit arising on sale of immovable property must be recognised and taxed in the year of actual sale (execution/registration of the sale deed) where risks and rewards transfer; ICDS III was held inapplicable to the assessee. Confirmed estimated unaccounted profit was permitted to be set off (telescoped) against additions for alleged advances/expenses, avoiding double taxation.
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