Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The ITAT upheld the CIT(A)'s deletion of additions relating to excess production, bogus purchases, and extra sales, directing the AO to accept the assessee's disclosed yield percentage and delete the corresponding additions. Additions on alleged bogus liability and freight & cartage expenses were remanded to the CIT(A) for de novo adjudication with a directive to provide reasonable opportunity to both parties. Disallowances of entertainment, telephone, generator, motor vehicle, and petrol expenses were restricted to 5% of the total claim, following precedent from the coordinate bench. The tribunal found no distinguishable facts or legal grounds to deviate from prior rulings and emphasized adherence to procedural fairness and statutory provisions in reassessing the remanded issues.
The ITAT upheld the CIT(A)'s deletion of additions relating to excess production, bogus purchases, and extra sales, directing the AO to accept the assessee's disclosed yield percentage and delete the corresponding additions. Additions on alleged bogus liability and freight & cartage expenses were remanded to the CIT(A) for de novo adjudication with a directive to provide reasonable opportunity to both parties. Disallowances of entertainment, telephone, generator, motor vehicle, and petrol expenses were restricted to 5% of the total claim, following precedent from the coordinate bench. The tribunal found no distinguishable facts or legal grounds to deviate from prior rulings and emphasized adherence to procedural fairness and statutory provisions in reassessing the remanded issues.
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