Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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