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Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Assessee was the founder and Managing Director of a company engaged in export of spices, pickles etc. Approximately 98% of the company's revenue came from exports. As the Managing Director, assessee was required to travel abroad, and the company reimbursed expenses incurred for official purposes directly to credit card companies as per policy. Considering the company's substantial export turnover of Rs. 159 crores, confirmation that reimbursements were for official visits, personal expenses not reimbursed, and travel expenses of only Rs. 4 crores against turnover, ITAT held that the addition made by the AO is liable to be deleted and decided in favour of the assessee.
Assessee was the founder and Managing Director of a company engaged in export of spices, pickles etc. Approximately 98% of the company's revenue came from exports. As the Managing Director, assessee was required to travel abroad, and the company reimbursed expenses incurred for official purposes directly to credit card companies as per policy. Considering the company's substantial export turnover of Rs. 159 crores, confirmation that reimbursements were for official visits, personal expenses not reimbursed, and travel expenses of only Rs. 4 crores against turnover, ITAT held that the addition made by the AO is liable to be deleted and decided in favour of the assessee.
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