Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
ITAT allowed the assessee's appeal, rejecting the Assessing Officer's (AO) arbitrary estimation of gross profit. The tribunal found no material defects in the books of accounts, no evidence of sales suppression, and no new land purchases. The AO's rejection of accounts solely based on lower gross profit compared to previous years was deemed incorrect. Without comparable industry data or market survey to justify the 9.94% gross profit estimation, the tribunal concluded that the addition to income was unwarranted. The decision was consistent with prior scrutiny assessments where the assessee's returned income was accepted with minimal adjustments.
ITAT allowed the assessee's appeal, rejecting the Assessing Officer's (AO) arbitrary estimation of gross profit. The tribunal found no material defects in the books of accounts, no evidence of sales suppression, and no new land purchases. The AO's rejection of accounts solely based on lower gross profit compared to previous years was deemed incorrect. Without comparable industry data or market survey to justify the 9.94% gross profit estimation, the tribunal concluded that the addition to income was unwarranted. The decision was consistent with prior scrutiny assessments where the assessee's returned income was accepted with minimal adjustments.
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