Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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