Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcemen...
Disallowance under tax law for investment expenses cannot be applied mechanically; authority must record clear reasons before increasing assessee's su...
Addressing disputed purchases and commission claims, the note holds that where sales and business are accepted, purchases cannot be treated as wholly non-existent and an addition should be limited to the profit element; accordingly purchases from two suppliers (where statutory notices were unserved) were estimated at the declared gross profit rate of 6.5% to account for possible embedded profit and price inflation. Separately, commission and brokerage payments were held allowable where primary documentary evidence (ledgers, bills, bank payments, TDS proof) was produced and no independent adverse material or enquiries proved the payments were sham, so full disallowance was not justified.
Addressing disputed purchases and commission claims, the note holds that where sales and business are accepted, purchases cannot be treated as wholly non-existent and an addition should be limited to the profit element; accordingly purchases from two suppliers (where statutory notices were unserved) were estimated at the declared gross profit rate of 6.5% to account for possible embedded profit and price inflation. Separately, commission and brokerage payments were held allowable where primary documentary evidence (ledgers, bills, bank payments, TDS proof) was produced and no independent adverse material or enquiries proved the payments were sham, so full disallowance was not justified.
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