Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
ITAT allowed the appeal of the assessee and set aside the assessing officer's rejection of books and deemed income estimate of 2% of sales, holding that the assessee operated as a pass-through processor with negligible control and thin purchase-commission margins. The Tribunal found the assessee regularly declared gross profit of c.0.29% and noted the AO ought to have examined the buyer group by issuing notice under s.133(6). Having regard to comparable precedents and the assessee's scale vis-Ã -vis large group operations, the ITAT fixed estimated profit at 0.40% of gross sales and directed consequential relief, thereby allowing the appeal.
ITAT allowed the appeal of the assessee and set aside the assessing officer's rejection of books and deemed income estimate of 2% of sales, holding that the assessee operated as a pass-through processor with negligible control and thin purchase-commission margins. The Tribunal found the assessee regularly declared gross profit of c.0.29% and noted the AO ought to have examined the buyer group by issuing notice under s.133(6). Having regard to comparable precedents and the assessee's scale vis-Ã -vis large group operations, the ITAT fixed estimated profit at 0.40% of gross sales and directed consequential relief, thereby allowing the appeal.
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