Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
In retail liquor business out-of-books transactions, only the profit element embedded in the unaccounted activity was held taxable, not the gross purchases or duplicated sales stream. The Tribunal found a close nexus between unaccounted purchases, unaccounted sales and cash collections, and restricted the addition to 3% of the relevant unaccounted transactions while deleting the separate substantive and protective additions based on gross purchases and related advances. It further held that cash already deposited in regular bank accounts could not again be treated as unaccounted sales, so the balance alone was subject to 3% estimation. Cash found at the premises was also deleted where the cash book explained availability and telescoping of estimated income was accepted.
In retail liquor business out-of-books transactions, only the profit element embedded in the unaccounted activity was held taxable, not the gross purchases or duplicated sales stream. The Tribunal found a close nexus between unaccounted purchases, unaccounted sales and cash collections, and restricted the addition to 3% of the relevant unaccounted transactions while deleting the separate substantive and protective additions based on gross purchases and related advances. It further held that cash already deposited in regular bank accounts could not again be treated as unaccounted sales, so the balance alone was subject to 3% estimation. Cash found at the premises was also deleted where the cash book explained availability and telescoping of estimated income was accepted.
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