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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Books of account cannot be rejected merely because some invoices were not produced or suppliers did not respond to notices under section 133(6), where no specific defect or deficiency is found in the accounts. The Tribunal noted that the assessee's sales pattern showed consistency and that the AO had not identified any concrete infirmity in the maintained books. Estimation of profit at 8% of turnover was therefore unsustainable, and the addition based on wrongful rejection of books was deleted. The CIT(A)'s order upholding the assessment was set aside.
Books of account cannot be rejected merely because some invoices were not produced or suppliers did not respond to notices under section 133(6), where no specific defect or deficiency is found in the accounts. The Tribunal noted that the assessee's sales pattern showed consistency and that the AO had not identified any concrete infirmity in the maintained books. Estimation of profit at 8% of turnover was therefore unsustainable, and the addition based on wrongful rejection of books was deleted. The CIT(A)'s order upholding the assessment was set aside.
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