Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Assessee surrendered additional income during search, leading to issues regarding valuation of jewelry stock and taxation u/s 115BBE. Tribunal held additional income should be taxed as business income at normal rates, not 60% u/s 115BBE, as the relevant amendment came after the search date. Cash deposits during demonetization were accepted as books weren't rejected, cash sales were reduced from stock, and turnover increase was justified. Disallowance of advertisement expenses on ad-hoc basis was deleted as books weren't rejected u/s 145(3) and payments were made through account payee cheques after TDS deduction. Assessee's contentions were upheld by the Tribunal.
Assessee surrendered additional income during search, leading to issues regarding valuation of jewelry stock and taxation u/s 115BBE. Tribunal held additional income should be taxed as business income at normal rates, not 60% u/s 115BBE, as the relevant amendment came after the search date. Cash deposits during demonetization were accepted as books weren't rejected, cash sales were reduced from stock, and turnover increase was justified. Disallowance of advertisement expenses on ad-hoc basis was deleted as books weren't rejected u/s 145(3) and payments were made through account payee cheques after TDS deduction. Assessee's contentions were upheld by the Tribunal.
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