Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Profit estimation on unaccounted turnover: AO estimated 8% profit based on seized material, which was reduced to 5% by CIT(A). ITAT held that in case of profit estimation u/s 145, Revenue must make an honest and fair estimate by applying the profit rate declared in preceding years. Considering the assessee's business of trading in Kirana items, ITAT opined that 4% profit amounting to Rs. 35,70,673 shall meet justice. Since Rs. 75 lakh was offered for taxation as business income, the additional profit needs to be telescoped with the offered income, and no separate addition is required. Unexplained expenditure: Assessee argued that once books were rejected and profits estimated on turnover, expenses for earning such profits should be considered, and any addition for expenses would amount to double addition. ITAT held that the expenditure on unrecorded cash coupons is treated as unexplained expenditure u/s 69C and taxed at 60% u/s 115BBE. However, the basic invocation of Section 69C based on estimates is uncalled for. CIT(A) appropriately decided, and ITAT upheld the order. 4% net profit on turnover: ITAT found that CIT(A) correctly considered the additional income of Rs. 75.
Profit estimation on unaccounted turnover: AO estimated 8% profit based on seized material, which was reduced to 5% by CIT(A). ITAT held that in case of profit estimation u/s 145, Revenue must make an honest and fair estimate by applying the profit rate declared in preceding years. Considering the assessee's business of trading in Kirana items, ITAT opined that 4% profit amounting to Rs. 35,70,673 shall meet justice. Since Rs. 75 lakh was offered for taxation as business income, the additional profit needs to be telescoped with the offered income, and no separate addition is required. Unexplained expenditure: Assessee argued that once books were rejected and profits estimated on turnover, expenses for earning such profits should be considered, and any addition for expenses would amount to double addition. ITAT held that the expenditure on unrecorded cash coupons is treated as unexplained expenditure u/s 69C and taxed at 60% u/s 115BBE. However, the basic invocation of Section 69C based on estimates is uncalled for. CIT(A) appropriately decided, and ITAT upheld the order. 4% net profit on turnover: ITAT found that CIT(A) correctly considered the additional income of Rs. 75.
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