Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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Ad hoc disallowance of business expenditure was deleted because the assessee had produced books of account, bills, vouchers, stock register, purchase details, bank statements and expense vouchers, and the books were not rejected under section 145(3). In respect of purchases from one supplier, the estimated profit addition was deleted in full because payments were through banking channels, supporting records were filed, notices were replied to by the supplier confirming the transactions, and there was no evidence of cash return or doubt about corresponding sales. For another supplier, only the embedded profit in the disputed purchases was brought to tax as grey market purchases, and the addition was restricted to 2 per cent.
Ad hoc disallowance of business expenditure was deleted because the assessee had produced books of account, bills, vouchers, stock register, purchase details, bank statements and expense vouchers, and the books were not rejected under section 145(3). In respect of purchases from one supplier, the estimated profit addition was deleted in full because payments were through banking channels, supporting records were filed, notices were replied to by the supplier confirming the transactions, and there was no evidence of cash return or doubt about corresponding sales. For another supplier, only the embedded profit in the disputed purchases was brought to tax as grey market purchases, and the addition was restricted to 2 per cent.
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