Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Ad hoc gross profit estimation was held inappropriate where the Revenue sought to reject books of account after a survey and treat surrendered excess stock as a basis for additional income. The Tribunal noted that gross profit rates may vary between pre-survey and post-survey periods because market prices fluctuate, and that excess stock found in survey must be brought into the books and reflected in closing stock at the lower of cost or market price under AS-2. On that reasoning, the books could not be rejected on the stated grounds and the addition founded on ad hoc gross profit estimation was not sustainable.
Ad hoc gross profit estimation was held inappropriate where the Revenue sought to reject books of account after a survey and treat surrendered excess stock as a basis for additional income. The Tribunal noted that gross profit rates may vary between pre-survey and post-survey periods because market prices fluctuate, and that excess stock found in survey must be brought into the books and reflected in closing stock at the lower of cost or market price under AS-2. On that reasoning, the books could not be rejected on the stated grounds and the addition founded on ad hoc gross profit estimation was not sustainable.
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