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    <title>2025 (12) TMI 1695 - ITAT SURAT</title>
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    <description>Faceless assessment was not vitiated under s.144B or CBDT instructions because statutory notices were issued, the proposed disallowance was put to the taxpayer, and no specific prejudice (rejection of evidence/adjournment) was demonstrated; the assessment was upheld as valid. On deductibility of additional sugarcane price over FRP, the Tribunal held that, absent contemporaneous Government approval and cost-based justification, disallowance in principle could be warranted and any computation must follow the benchmark-differential method aligned with SC principles; however, for the relevant year the taxpayer produced unrebutted State Government approval of the final cane price satisfying s.36(1)(xvii), making further &quot;profit-embedded&quot; segregation inapplicable, so the disallowance was deleted. Set-off of brought-forward unabsorbed depreciation was directed to be allowed.</description>
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    <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1695 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=784155</link>
      <description>Faceless assessment was not vitiated under s.144B or CBDT instructions because statutory notices were issued, the proposed disallowance was put to the taxpayer, and no specific prejudice (rejection of evidence/adjournment) was demonstrated; the assessment was upheld as valid. On deductibility of additional sugarcane price over FRP, the Tribunal held that, absent contemporaneous Government approval and cost-based justification, disallowance in principle could be warranted and any computation must follow the benchmark-differential method aligned with SC principles; however, for the relevant year the taxpayer produced unrebutted State Government approval of the final cane price satisfying s.36(1)(xvii), making further &quot;profit-embedded&quot; segregation inapplicable, so the disallowance was deleted. Set-off of brought-forward unabsorbed depreciation was directed to be allowed.</description>
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      <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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