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...
Estimation of Profit/Section 40A(2)(b) - JV entered - sub-contracting - AO had formed a view that the assessee JV had suppressed its profit by making excessive payment to TPPL - the section 40A(2)(b) has no application to income aspect of the assessee JV in the facts of the instant case. The AO has not brought any comparable figures to disallow the expenditure, moreover with the structuring of the JV provisions of Section 40A(2)(b) are not attracted in the given facts and circumstances of the instant case. - Additions deleted - AT
Estimation of Profit/Section 40A(2)(b) - JV entered - sub-contracting - AO had formed a view that the assessee JV had suppressed its profit by making excessive payment to TPPL - the section 40A(2)(b) has no application to income aspect of the assessee JV in the facts of the instant case. The AO has not brought any comparable figures to disallow the expenditure, moreover with the structuring of the JV provisions of Section 40A(2)(b) are not attracted in the given facts and circumstances of the instant case. - Additions deleted - AT
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