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...
The ITAT Delhi held that no addition u/s 68 was warranted as there was no abnormal jump in sales, with audited results and profits undisputed. The difference in cash deposits was found to be reconciled, leading to allowance of the assessee's appeal. Regarding disallowance u/s 40A(3) for cash purchases over Rs. 20,000, it was noted that no specific instances were provided by the AO, and the total cash purchases were deemed reasonable at 2.6% of turnover. As no contravention of Section 40A(3) was evidenced, the appeal of the assessee was allowed.
The ITAT Delhi held that no addition u/s 68 was warranted as there was no abnormal jump in sales, with audited results and profits undisputed. The difference in cash deposits was found to be reconciled, leading to allowance of the assessee's appeal. Regarding disallowance u/s 40A(3) for cash purchases over Rs. 20,000, it was noted that no specific instances were provided by the AO, and the total cash purchases were deemed reasonable at 2.6% of turnover. As no contravention of Section 40A(3) was evidenced, the appeal of the assessee was allowed.
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