Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
Inflated purchase additions attributed to a foreign procurement facilitator were deleted because the entity was separately incorporated, had disclosed its commission income in Singapore, and the Revenue produced no cogent evidence of sham, colourable device, price inflation, fund flow-back, or accrual of the commission income to the assessees; suspicion and uncorroborated statements could not sustain the addition. The Tribunal also treated export incentives as operating income under TNMM, held that persistent loss filters require sustained losses, and applied consistent operating treatment to routine expenses, bad debts, rates and taxes, and marketing commission. It further deleted the section 40A(3) disallowance while confirming a limited disallowance of unsupported expenditure.
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