Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
The ITAT held that a reasonable gross profit rate of 2% should be applied on unaccounted purchases of gold, instead of the AO's net profit rate of 12%. The disallowance u/s 40A(3) was deleted as the income was assessed applying the flat gross profit rate. The addition for excess stock jewellery was set aside and remanded to the AO for fresh adjudication after verifying the invoices filed by the assessee.
The ITAT held that a reasonable gross profit rate of 2% should be applied on unaccounted purchases of gold, instead of the AO's net profit rate of 12%. The disallowance u/s 40A(3) was deleted as the income was assessed applying the flat gross profit rate. The addition for excess stock jewellery was set aside and remanded to the AO for fresh adjudication after verifying the invoices filed by the assessee.
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