Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Unreliable salary records justified rejection of the books of account where discrepancies in wage and salary registers remained unexplained, including mismatches with profit and loss account entries, inconsistent signatures, missing names and addresses, and unsupported cash payments. Once the books were rejected, profit had to be estimated on a rational basis; an 8 per cent net profit rate was held arbitrary because no justification was shown. The assessee's past net profit history of about 1 to 2 per cent was treated as the proper guide, and net profit was directed to be computed at 3 per cent of turnover.
Unreliable salary records justified rejection of the books of account where discrepancies in wage and salary registers remained unexplained, including mismatches with profit and loss account entries, inconsistent signatures, missing names and addresses, and unsupported cash payments. Once the books were rejected, profit had to be estimated on a rational basis; an 8 per cent net profit rate was held arbitrary because no justification was shown. The assessee's past net profit history of about 1 to 2 per cent was treated as the proper guide, and net profit was directed to be computed at 3 per cent of turnover.
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