Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Assessee, a distributor of SIM cards and vouchers for Vodafone Mobile Services Limited, earned commission on sales to retail shops. Cash deposits were considered business receipts reinvested in purchasing new SIM cards and vouchers, with consistent fund rotation reflected in bank statements provided to authorities. CIT(A) erred in treating entire sales as income without considering business turnover and payments to Vodafone. ITAT directed AO to calculate estimated profit at 1% on transactions, quashing addition u/s 69A as source of deposits was established. Interest u/ss 234A, 234B, and 234C was denied due to income below taxable limit. ITAT emphasized careful handling of such cases by AOs as adjudicators and investigators. Assessee's appeal was allowed, providing relief from addition of Rs. 1,51,77,749.
Assessee, a distributor of SIM cards and vouchers for Vodafone Mobile Services Limited, earned commission on sales to retail shops. Cash deposits were considered business receipts reinvested in purchasing new SIM cards and vouchers, with consistent fund rotation reflected in bank statements provided to authorities. CIT(A) erred in treating entire sales as income without considering business turnover and payments to Vodafone. ITAT directed AO to calculate estimated profit at 1% on transactions, quashing addition u/s 69A as source of deposits was established. Interest u/ss 234A, 234B, and 234C was denied due to income below taxable limit. ITAT emphasized careful handling of such cases by AOs as adjudicators and investigators. Assessee's appeal was allowed, providing relief from addition of Rs. 1,51,77,749.
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