Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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