Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The ITAT, an Appellate Tribunal, addressed the issue of determining income from futures transactions. The Tribunal held that the AO's addition lacked transparency as no information on the alleged transaction was shared. The CIT(A) accepted the turnover disclosed by the assessee but unreasonably applied a 50% profit rate. Given the acceptance of turnover and the assessee's choice of presumptive taxation u/s 44AD, the statutory 8% profit rate should apply. Consequently, the assessee's appeal was allowed.
The ITAT, an Appellate Tribunal, addressed the issue of determining income from futures transactions. The Tribunal held that the AO's addition lacked transparency as no information on the alleged transaction was shared. The CIT(A) accepted the turnover disclosed by the assessee but unreasonably applied a 50% profit rate. Given the acceptance of turnover and the assessee's choice of presumptive taxation u/s 44AD, the statutory 8% profit rate should apply. Consequently, the assessee's appeal was allowed.
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