Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT allowed the appeal of the assessee, deleting the addition made by the AO on account of alleged excess purchases based on differences between VAT returns and books of account. ITAT held that, under the applicable VAT Rules, mandatory reversal of input tax credit on goods returned necessarily causes variations between VAT records and commercial books, without implying inflation of purchases. The assessee's supplier-wise reconciliation was found credible, and no material was brought by the AO to establish bogus or unverifiable purchases. With sales figures matching in both records and the variation being less than one percent of total purchases, ITAT found the disallowance by AO and its confirmation by CIT(A) unjustified.
ITAT allowed the appeal of the assessee, deleting the addition made by the AO on account of alleged excess purchases based on differences between VAT returns and books of account. ITAT held that, under the applicable VAT Rules, mandatory reversal of input tax credit on goods returned necessarily causes variations between VAT records and commercial books, without implying inflation of purchases. The assessee's supplier-wise reconciliation was found credible, and no material was brought by the AO to establish bogus or unverifiable purchases. With sales figures matching in both records and the variation being less than one percent of total purchases, ITAT found the disallowance by AO and its confirmation by CIT(A) unjustified.
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