Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Estimation of income - bogus purchases - quantification of profit - The Tribunal noted that during investigations, the alleged suppliers were identified as bogus entities involved in issuing fake invoices without actual delivery of goods. Despite the taxpayer’s claims of making payments through banking channels, the assessing officer found no credible evidence to support the genuineness of the transactions. Consequently, the Tribunal agreed with the lower authorities in treating these purchases as bogus but redirected the case to assess the exact profit element attributable to these transactions, aligning with the principle that only the profit margin on such bogus transactions should be added to taxable income.
Estimation of income - bogus purchases - quantification of profit - The Tribunal noted that during investigations, the alleged suppliers were identified as bogus entities involved in issuing fake invoices without actual delivery of goods. Despite the taxpayer’s claims of making payments through banking channels, the assessing officer found no credible evidence to support the genuineness of the transactions. Consequently, the Tribunal agreed with the lower authorities in treating these purchases as bogus but redirected the case to assess the exact profit element attributable to these transactions, aligning with the principle that only the profit margin on such bogus transactions should be added to taxable income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
