Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.
Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.
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