Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The principal issue was whether books of account could be rejected under s.145 for non-maintenance of item-wise and month-wise stock registers and whether a gross profit estimate could be raised. The Tribunal held that where audited regular books exist, physical year-end stock verification is conducted, major consumable quantities are recorded, and no inflation of purchases or suppression of sales is found, mere non-maintenance of a particular stock register format is not a valid ground to reject accounts; reliance on precedent affirmed this legal basis. Consequently, the arbitrary uplift of gross profit from ~8.5% to 11% and rejection under s.145 were unsustainable and deleted. - ITAT
The principal issue was whether books of account could be rejected under s.145 for non-maintenance of item-wise and month-wise stock registers and whether a gross profit estimate could be raised. The Tribunal held that where audited regular books exist, physical year-end stock verification is conducted, major consumable quantities are recorded, and no inflation of purchases or suppression of sales is found, mere non-maintenance of a particular stock register format is not a valid ground to reject accounts; reliance on precedent affirmed this legal basis. Consequently, the arbitrary uplift of gross profit from ~8.5% to 11% and rejection under s.145 were unsustainable and deleted. - ITAT
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