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    <title>2021 (10) TMI 449 - ITAT CHENNAI</title>
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    <description>An addition for alleged suppression or excess production of IMFL cannot rest on mere extrapolation from caps, bottles or spirit consumption discrepancies unless supported by cogent evidence of clandestine production or removal and a realistic appraisal of the manufacturing process. Landscaping charges were treated as recurring operational expenditure, not capital outlay, because no enduring capital asset or advantage was shown. Bottle-cost inflation additions failed where supplier pricing differences were not shown to involve comparable goods or cash recycling. Finance charges were disallowed to the extent borrowed funds were diverted for non-business purposes. Cash discount on sales was accepted as a genuine commercial term, and landscaping expense remained allowable.</description>
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      <description>An addition for alleged suppression or excess production of IMFL cannot rest on mere extrapolation from caps, bottles or spirit consumption discrepancies unless supported by cogent evidence of clandestine production or removal and a realistic appraisal of the manufacturing process. Landscaping charges were treated as recurring operational expenditure, not capital outlay, because no enduring capital asset or advantage was shown. Bottle-cost inflation additions failed where supplier pricing differences were not shown to involve comparable goods or cash recycling. Finance charges were disallowed to the extent borrowed funds were diverted for non-business purposes. Cash discount on sales was accepted as a genuine commercial term, and landscaping expense remained allowable.</description>
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