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...
A provisional stock statement furnished to a bank for cash credit purposes could not displace audited closing stock where the Assessing Officer found no defect in the books, stock records, or valuation method and did not reject the accounts. The Tribunal accepted that the banking figures were estimated and also materially differed in sales, debtors, and creditors, showing they were not final accounts. It further held that any increase in closing stock would require a corresponding opening stock adjustment in the next year, making the proposed addition revenue-neutral where the tax rate and positive taxable income remained the same. The addition was therefore deleted.
A provisional stock statement furnished to a bank for cash credit purposes could not displace audited closing stock where the Assessing Officer found no defect in the books, stock records, or valuation method and did not reject the accounts. The Tribunal accepted that the banking figures were estimated and also materially differed in sales, debtors, and creditors, showing they were not final accounts. It further held that any increase in closing stock would require a corresponding opening stock adjustment in the next year, making the proposed addition revenue-neutral where the tax rate and positive taxable income remained the same. The addition was therefore deleted.
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