Delayed judgment pronouncement alone does not invalidate Tribunal orders, while rectification cannot reopen evidence or negate confiscation-related pe...
Agricultural-land reinvestment qualifies when transfer consideration precedes replacement purchase, while unexamined claims may be reassessed on escap...
Bona fide public fixed-deposit explanations prevent concealment penalties where unexplained-credit additions lack independent evidence of undisclosed ...
Berry ratio is unsuitable as a profit level indicator for a jewellery manufacturer that bears material, inventory, price and manufacturing risks, because value-added expenses exclude material costs, capital deployment and risks; total cost is the more reliable base. Sales transfer-pricing adjustments based on that ratio were deleted. Notional interest on associated-enterprise receivables requires parity analysis against unrelated customers: where identical 180-day, interest-free credit terms applied, the adjustment was deleted. For a later year, verification was required and any interest confined to delays beyond 180 days at six-month LIBOR plus verified bank spread. Transfer-pricing adjustments could not be included in book profit contrary to binding directions.
Berry ratio is unsuitable as a profit level indicator for a jewellery manufacturer that bears material, inventory, price and manufacturing risks, because value-added expenses exclude material costs, capital deployment and risks; total cost is the more reliable base. Sales transfer-pricing adjustments based on that ratio were deleted. Notional interest on associated-enterprise receivables requires parity analysis against unrelated customers: where identical 180-day, interest-free credit terms applied, the adjustment was deleted. For a later year, verification was required and any interest confined to delays beyond 180 days at six-month LIBOR plus verified bank spread. Transfer-pricing adjustments could not be included in book profit contrary to binding directions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
