Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Whether additions for alleged contrived/fictitious NMCE commodity transactions were sustainable - held that the assessee had declared profits and furnished complete corroborative records (contract notes, broker ledgers, confirmations, bank statements, books) which matched NMCE data obtained u/s 133(6); AO did not identify any discrepancy nor produce independent evidence of fabrication, relying instead on general investigation inputs and selectively deeming parts of the same transactions non-genuine; conclusion: additions lacked factual and legal basis and were deleted. - ITAT
Whether additions for alleged contrived/fictitious NMCE commodity transactions were sustainable - held that the assessee had declared profits and furnished complete corroborative records (contract notes, broker ledgers, confirmations, bank statements, books) which matched NMCE data obtained u/s 133(6); AO did not identify any discrepancy nor produce independent evidence of fabrication, relying instead on general investigation inputs and selectively deeming parts of the same transactions non-genuine; conclusion: additions lacked factual and legal basis and were deleted. - ITAT
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