Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.
Net profit estimation for a vegetable commission business must reflect the nature of commission activity and available material after cash deposits are accepted as business turnover. Relevant considerations include loading and unloading, salary and administrative expenses, and income results accepted for the succeeding assessment year and another comparable business assessment, without mechanically applying those comparables. Incomplete records and transaction volume do not justify reduction merely on a general claim. Business income was recomputed by applying a 2% net profit rate to accepted business receipts.
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