Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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