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...
Rejection of the books of account of the assessee company u/s. 145(3) - Estimation of income - The ITAT found the rejection of books of accounts by the AO unjustified as there was no evidence of incorrectness or incompleteness. - The AO's reliance on media clippings and reports without concrete proof was deemed insufficient to reject the books. - On the issue of cash deposits during demonetization, the Tribunal noted that the Assessing Officer's presumption of antedating sales and earning super profits lacked substantiation and relied heavily on speculation. - The Tribunal rejected the AO's presumption of a 25% profit margin on sales and found no basis for the addition.
Rejection of the books of account of the assessee company u/s. 145(3) - Estimation of income - The ITAT found the rejection of books of accounts by the AO unjustified as there was no evidence of incorrectness or incompleteness. - The AO's reliance on media clippings and reports without concrete proof was deemed insufficient to reject the books. - On the issue of cash deposits during demonetization, the Tribunal noted that the Assessing Officer's presumption of antedating sales and earning super profits lacked substantiation and relied heavily on speculation. - The Tribunal rejected the AO's presumption of a 25% profit margin on sales and found no basis for the addition.
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