Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
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