Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
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