Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
ITAT modified the order of the Ld. CIT(A), holding that discrepancies in a third-party GST return cannot alone sustain an addition under s. 69C. The Tribunal found admitted purchases of Rs. 30,42,821 (not Rs. 76,10,580) and concluded the Assessing Officer's estimate was excessive. ITAT directed the AO to compute unexplained income by applying a gross profit rate of 5% on the admitted total purchases, thereby reducing the addition previously upheld by the CIT(A). The appeal of the assessee is partly allowed and remitted for assessment in accordance with this direction.
ITAT modified the order of the Ld. CIT(A), holding that discrepancies in a third-party GST return cannot alone sustain an addition under s. 69C. The Tribunal found admitted purchases of Rs. 30,42,821 (not Rs. 76,10,580) and concluded the Assessing Officer's estimate was excessive. ITAT directed the AO to compute unexplained income by applying a gross profit rate of 5% on the admitted total purchases, thereby reducing the addition previously upheld by the CIT(A). The appeal of the assessee is partly allowed and remitted for assessment in accordance with this direction.
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