Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
ITAT deleted additions for alleged bogus purchases of capital assets and other purchases because the assessee substantiated genuineness with invoices, transport documents, bank loan agreement, bank statements and an insurance policy issued after physical inspection of the assets. The tribunal held that the assets were financed by the bank and were in existence, which contradicted the allegation of accommodation entries. It also noted that the assessee had not claimed the capital asset purchases as revenue expenditure in the profit and loss account, and the Assessing Officer relied only on unverified information without independent inquiry. On these facts, the purchases were not bogus and the additions were deleted.
ITAT deleted additions for alleged bogus purchases of capital assets and other purchases because the assessee substantiated genuineness with invoices, transport documents, bank loan agreement, bank statements and an insurance policy issued after physical inspection of the assets. The tribunal held that the assets were financed by the bank and were in existence, which contradicted the allegation of accommodation entries. It also noted that the assessee had not claimed the capital asset purchases as revenue expenditure in the profit and loss account, and the Assessing Officer relied only on unverified information without independent inquiry. On these facts, the purchases were not bogus and the additions were deleted.
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