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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
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