Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
Revenue's appeal before ITAT was dismissed. ITAT upheld CIT(A)'s acceptance of additional evidence under Rule 46A, noting that the material was remanded to the AO and no remand report was furnished despite repeated reminders; thus there was no violation of Rule 46A. On merits, ITAT sustained CIT(A)'s deletion of additions relating to discrepancies in sales turnover, trade payables, and current liabilities, finding that reconciliations, third-party confirmations under s.133(6), and supporting records fully justified the assessee's position. ITAT also affirmed deletion of addition towards exceptional charges/expenses, holding that the assessee had already made a suo motu disallowance under s.37 and any further disallowance would result in double addition.
Revenue's appeal before ITAT was dismissed. ITAT upheld CIT(A)'s acceptance of additional evidence under Rule 46A, noting that the material was remanded to the AO and no remand report was furnished despite repeated reminders; thus there was no violation of Rule 46A. On merits, ITAT sustained CIT(A)'s deletion of additions relating to discrepancies in sales turnover, trade payables, and current liabilities, finding that reconciliations, third-party confirmations under s.133(6), and supporting records fully justified the assessee's position. ITAT also affirmed deletion of addition towards exceptional charges/expenses, holding that the assessee had already made a suo motu disallowance under s.37 and any further disallowance would result in double addition.
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