Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT
Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT
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