Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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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