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...
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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