Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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ITAT adjudicated a tax dispute concerning alleged bogus purchases and income estimation. The tribunal found no evidence of undervalued sales or inflated purchases after examining documentary proof of raw material delivery to the assessee's factory in Himachal Pradesh. The CIT(A) had previously accepted the assessee's books of accounts. The tribunal dismissed the department's appeal, ruling that applying a 5.94% gross profit rate on alleged bogus purchases was unjustified. The court determined that purchases were made at par or lower rates compared to other transactions, negating potential additional income. Consequently, the tribunal allowed the assessee's appeal and rejected the department's claim of embedded profits in the contested purchases.
ITAT adjudicated a tax dispute concerning alleged bogus purchases and income estimation. The tribunal found no evidence of undervalued sales or inflated purchases after examining documentary proof of raw material delivery to the assessee's factory in Himachal Pradesh. The CIT(A) had previously accepted the assessee's books of accounts. The tribunal dismissed the department's appeal, ruling that applying a 5.94% gross profit rate on alleged bogus purchases was unjustified. The court determined that purchases were made at par or lower rates compared to other transactions, negating potential additional income. Consequently, the tribunal allowed the assessee's appeal and rejected the department's claim of embedded profits in the contested purchases.
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