Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the absence of crucial documentation, such as delivery challans, to substantiate the purchases. Consequently, the disallowance of purchases was upheld. - Considering the appellant's argument for a lower percentage of disallowance based on the profit margin accepted in other assessment years, the Tribunal decided to restrict the disallowance to 5% of the disputed purchases, consistent with previous decisions in the appellant's case.
Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the absence of crucial documentation, such as delivery challans, to substantiate the purchases. Consequently, the disallowance of purchases was upheld. - Considering the appellant's argument for a lower percentage of disallowance based on the profit margin accepted in other assessment years, the Tribunal decided to restrict the disallowance to 5% of the disputed purchases, consistent with previous decisions in the appellant's case.
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