Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
