Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
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