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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The assessee declared purchases from parties issuing bogus purchase vouchers without actual transactions, merely laundering unaccounted money to claim deduction u/s 80HHC. The Assessing Officer treated 25% of unverifiable purchases as income from other sources, alleging inflation of export profits. The CIT(A) confirmed this addition. The ITAT held that rejection of books u/s 145(3) requires specific conditions, which were not satisfied. The AO did not follow the proper procedure or point out defects in accounts. The ITAT relied on judicial precedents to conclude that no addition can be made if the declared gross profit rate is higher than the rate prescribed by the jurisdictional High Court in such cases. The assessee's gross profit rate was found reasonable based on comparable cases and the partner's statement recorded during the search. Consequently, the ITAT allowed the assessee's ground and deleted the addition of 25% of unverifiable purchases.
The assessee declared purchases from parties issuing bogus purchase vouchers without actual transactions, merely laundering unaccounted money to claim deduction u/s 80HHC. The Assessing Officer treated 25% of unverifiable purchases as income from other sources, alleging inflation of export profits. The CIT(A) confirmed this addition. The ITAT held that rejection of books u/s 145(3) requires specific conditions, which were not satisfied. The AO did not follow the proper procedure or point out defects in accounts. The ITAT relied on judicial precedents to conclude that no addition can be made if the declared gross profit rate is higher than the rate prescribed by the jurisdictional High Court in such cases. The assessee's gross profit rate was found reasonable based on comparable cases and the partner's statement recorded during the search. Consequently, the ITAT allowed the assessee's ground and deleted the addition of 25% of unverifiable purchases.
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