https://www.taxtmi.com/caselaws?id=774893 ITAT Mumbai allowed revenue's appeal for statistical purposes and remanded the matter to CIT(A) for fresh adjudication. The case involved disallowance under section 40A(2)(a) where assessee purchased from related parties but failed to demonstrate arm's length pricing. The tribunal held that determination of fair market value requires factual inquiry into prevailing market rates, particularly for precious metals subject to daily fluctuations. Lower authorities erred by not examining objective market data or comparable transactions. AO's approach of computing disallowance based solely on gross profit rate decline without market evidence was unsustainable. CIT(A) must re-examine fair market value using contemporaneous data before determining any disallowance. en-us Mon, 30 Jun 2025 00:00:00 +0530 Wed, 16 Jul 2025 08:17:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774893 ITAT Mumbai allowed revenue's appeal for statistical purposes and remanded the matter to CIT(A) for fresh adjudication. The case involved disallowance under section 40A(2)(a) where assessee purchased from related parties but failed to demonstrate arm's length pricing. The tribunal held that determination of fair market value requires factual inquiry into prevailing market rates, particularly for precious metals subject to daily fluctuations. Lower authorities erred by not examining objective market data or comparable transactions. AO's approach of computing disallowance based solely on gross profit rate decline without market evidence was unsustainable. CIT(A) must re-examine fair market value using contemporaneous data before determining any disallowance. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774893