SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Unexplained expenditure - certain entries were found unmatched / not accounted for in the books of accounts in the expense ledger of the assessee - The assessee contended that the expenses were accounted for but not individually, and were incurred by employees at respective sites, later reimbursed by the assessee. However, the Tribunal (ITAT) found the explanation insufficient, emphasizing the need for proper documentation and evidence. While partially allowing the appeal, the tribunal imposed a restricted disallowance of 25% of the amount determined by the AO.
Unexplained expenditure - certain entries were found unmatched / not accounted for in the books of accounts in the expense ledger of the assessee - The assessee contended that the expenses were accounted for but not individually, and were incurred by employees at respective sites, later reimbursed by the assessee. However, the Tribunal (ITAT) found the explanation insufficient, emphasizing the need for proper documentation and evidence. While partially allowing the appeal, the tribunal imposed a restricted disallowance of 25% of the amount determined by the AO.
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