Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The case involves bogus purchases u/s 69C, with the assessee dealing in bullion. The Gross Profit (GP) rate estimation is crucial. The assessee argued that the GP rate for bullion cannot exceed 0.15%, supported by a demonstrated 0.13% GP rate on sales. It was shown that if purchases are deemed bogus, the GP percentage would unreasonably inflate to 26%. The addition of entire purchases was deemed unsustainable. Even if purchases were from other vendors, the maximum profit margin was held at 0.15%. The Appellate Tribunal directed the Assessing Officer to use a 0.15% GP rate for disputed purchases instead of the 0.13% claimed by the assessee, partly allowing the appeal.
The case involves bogus purchases u/s 69C, with the assessee dealing in bullion. The Gross Profit (GP) rate estimation is crucial. The assessee argued that the GP rate for bullion cannot exceed 0.15%, supported by a demonstrated 0.13% GP rate on sales. It was shown that if purchases are deemed bogus, the GP percentage would unreasonably inflate to 26%. The addition of entire purchases was deemed unsustainable. Even if purchases were from other vendors, the maximum profit margin was held at 0.15%. The Appellate Tribunal directed the Assessing Officer to use a 0.15% GP rate for disputed purchases instead of the 0.13% claimed by the assessee, partly allowing the appeal.
Note: It is a system-generated summary and is for quick reference only.