Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
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