Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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ITAT remanded the addition for alleged bogus purchases because the authorities had not first verified whether the disputed purchases were actually debited to the trading account or claimed as deduction; if they were not so claimed, the addition could not survive. The Tribunal also directed verification of the assessee's claim that genuine purchases from four parties existed and that the disputed amount had been reversed in the books. In contrast, a 50% disallowance of labour charges was sustained because the assessee produced only ledger entries and cash vouchers, without reliable evidence of the labourers' identity or other credible proof of expenditure.
ITAT remanded the addition for alleged bogus purchases because the authorities had not first verified whether the disputed purchases were actually debited to the trading account or claimed as deduction; if they were not so claimed, the addition could not survive. The Tribunal also directed verification of the assessee's claim that genuine purchases from four parties existed and that the disputed amount had been reversed in the books. In contrast, a 50% disallowance of labour charges was sustained because the assessee produced only ledger entries and cash vouchers, without reliable evidence of the labourers' identity or other credible proof of expenditure.
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