Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
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