Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Seized loose sheets, Rojmel, MITI and related digital records were held to have evidentiary value where the Assessing Officer had correlated them with each other and the assessees showed no specific defect or alternative explanation; retraction affidavits by employees did not neutralise the seized material. The Tribunal also rejected the claim that all entries were mere facilitation passes, holding that some reflected the assessees' own unaccounted sales and cash receipts. Profit, however, had to be estimated on a rational basis rather than guesswork: 4% was applied to undisclosed own transactions and cash sales, and 1.5% to facilitation-based transactions in the LLP matter, while 4% was applied to unaccounted cash sales of the trading concerns.
Seized loose sheets, Rojmel, MITI and related digital records were held to have evidentiary value where the Assessing Officer had correlated them with each other and the assessees showed no specific defect or alternative explanation; retraction affidavits by employees did not neutralise the seized material. The Tribunal also rejected the claim that all entries were mere facilitation passes, holding that some reflected the assessees' own unaccounted sales and cash receipts. Profit, however, had to be estimated on a rational basis rather than guesswork: 4% was applied to undisclosed own transactions and cash sales, and 1.5% to facilitation-based transactions in the LLP matter, while 4% was applied to unaccounted cash sales of the trading concerns.
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