Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The assessee's claim that bank credits were merely sale proceeds collected as a commission agent for farmers was rejected because no confirmations, agreements or other supporting material were produced. However, the estimate of profit at 12.5% of the total bank credits was held excessive, as the AO had not relied on comparable cases or other evidence to justify that rate. Following prior ITAT authority on fruits and vegetables trade, income was directed to be estimated at 4% of the total bank credits, and the addition was reduced accordingly.
The assessee's claim that bank credits were merely sale proceeds collected as a commission agent for farmers was rejected because no confirmations, agreements or other supporting material were produced. However, the estimate of profit at 12.5% of the total bank credits was held excessive, as the AO had not relied on comparable cases or other evidence to justify that rate. Following prior ITAT authority on fruits and vegetables trade, income was directed to be estimated at 4% of the total bank credits, and the addition was reduced accordingly.
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