Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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ITAT dismissed the Revenue's appeal and upheld in toto the order of the CIT(A) deleting the addition of Rs. 15.80 crore towards alleged bogus wage expenditure for A.Y. 2022-23 in the case of Assessee Co. ITAT held that the AO's reliance on cash scroll notings such as "MD Personal" was unsupported by any corroborative evidence, cash trail, or proof of personal use by the Managing Director, and that such private notings cannot, by themselves, constitute conclusive evidence of non-genuine expenditure. As the AO had not rejected the books under s.145, and the assessee's profit ratio was consistent with past years, the impugned disallowance was found arbitrary and unsustainable. All grounds raised by the Revenue were rejected.
ITAT dismissed the Revenue's appeal and upheld in toto the order of the CIT(A) deleting the addition of Rs. 15.80 crore towards alleged bogus wage expenditure for A.Y. 2022-23 in the case of Assessee Co. ITAT held that the AO's reliance on cash scroll notings such as "MD Personal" was unsupported by any corroborative evidence, cash trail, or proof of personal use by the Managing Director, and that such private notings cannot, by themselves, constitute conclusive evidence of non-genuine expenditure. As the AO had not rejected the books under s.145, and the assessee's profit ratio was consistent with past years, the impugned disallowance was found arbitrary and unsustainable. All grounds raised by the Revenue were rejected.
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