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...
Books of account cannot be rejected merely because some invoices were not produced or suppliers did not respond to notices under section 133(6), where no specific defect or deficiency is found in the accounts. The Tribunal noted that the assessee's sales pattern showed consistency and that the AO had not identified any concrete infirmity in the maintained books. Estimation of profit at 8% of turnover was therefore unsustainable, and the addition based on wrongful rejection of books was deleted. The CIT(A)'s order upholding the assessment was set aside.
Books of account cannot be rejected merely because some invoices were not produced or suppliers did not respond to notices under section 133(6), where no specific defect or deficiency is found in the accounts. The Tribunal noted that the assessee's sales pattern showed consistency and that the AO had not identified any concrete infirmity in the maintained books. Estimation of profit at 8% of turnover was therefore unsustainable, and the addition based on wrongful rejection of books was deleted. The CIT(A)'s order upholding the assessment was set aside.
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