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    <title>ITAT Allows Deletions of Gross Profit Additions and Foreign Creditor Claims Under Section 41(1)(a)</title>
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    <description>The ITAT upheld the deletion of additions related to the lower gross profit ratio, as the AO failed to provide requisite details or demonstrate defects in the appellant&#039;s manufacturing account, rendering the AO&#039;s 21% GP application unsustainable. Additions under section 41(1)(a) regarding four foreign creditors were also deleted, given the appellant&#039;s proof of genuine transactions, RBI approval, and corresponding sales, which the AO could not effectively rebut. The tribunal affirmed the CIT(A)&#039;s relief concerning interest to a partner, dismissing the Revenue&#039;s appeal. However, the addition related to one creditor, Sabar International, was sustained due to the appellant&#039;s silence on that issue. Overall, the appeal was allowed in part, with d.....</description>
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    <pubDate>Fri, 11 Jul 2025 08:39:54 +0530</pubDate>
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      <title>ITAT Allows Deletions of Gross Profit Additions and Foreign Creditor Claims Under Section 41(1)(a)</title>
      <link>https://www.taxtmi.com/highlights?id=90371</link>
      <description>The ITAT upheld the deletion of additions related to the lower gross profit ratio, as the AO failed to provide requisite details or demonstrate defects in the appellant&#039;s manufacturing account, rendering the AO&#039;s 21% GP application unsustainable. Additions under section 41(1)(a) regarding four foreign creditors were also deleted, given the appellant&#039;s proof of genuine transactions, RBI approval, and corresponding sales, which the AO could not effectively rebut. The tribunal affirmed the CIT(A)&#039;s relief concerning interest to a partner, dismissing the Revenue&#039;s appeal. However, the addition related to one creditor, Sabar International, was sustained due to the appellant&#039;s silence on that issue. Overall, the appeal was allowed in part, with d.....</description>
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