Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
The ITAT Jodhpur allowed admission of additional evidence u/r 46A of IT Rules by CIT(A) to delete addition on merits. The tribunal found merit in the evidence provided by the assessee regarding sales of bullion, criticizing the AO for not seeking further details. The revenue's objection to non-admission of evidence due to lack of documentation was dismissed. The CIT(A) rightly admitted additional evidence, rejecting the department's objection. Regarding unexplained cash deposits u/s 69A, the appellant explained deposits as sale proceeds from bullion trading, earning a 1% commission. The tribunal upheld CIT(A)'s decision to apply a net profit rate of 1% on total deposits, considering the nature of the business and standard accounting principles. CIT(A) applied a net profit rate of 1.2% to cover possible revenue leakages, which was deemed fair and reasonable. The tribunal upheld the application of the 1.2% NP rate for estimating commission earned on bullion sales.
The ITAT Jodhpur allowed admission of additional evidence u/r 46A of IT Rules by CIT(A) to delete addition on merits. The tribunal found merit in the evidence provided by the assessee regarding sales of bullion, criticizing the AO for not seeking further details. The revenue's objection to non-admission of evidence due to lack of documentation was dismissed. The CIT(A) rightly admitted additional evidence, rejecting the department's objection. Regarding unexplained cash deposits u/s 69A, the appellant explained deposits as sale proceeds from bullion trading, earning a 1% commission. The tribunal upheld CIT(A)'s decision to apply a net profit rate of 1% on total deposits, considering the nature of the business and standard accounting principles. CIT(A) applied a net profit rate of 1.2% to cover possible revenue leakages, which was deemed fair and reasonable. The tribunal upheld the application of the 1.2% NP rate for estimating commission earned on bullion sales.
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