Held that the Commissioner (Appeals) had observed that the assessee made a gross profit of 48 per cent. on products purchased for trading from its sister firm as compared to the gross profit of 46 per cent. on trading of products purchased from third parties. Thus, the Assessing Officer’s observation that some expenses were shifted from the hands of the firm to the assessee was not made out from the records. (AY.2012-13)
Intas Pharmaceuticals Ltd. v. ACIT (2024)114 ITR 546 (Ahd)(Trib)
S. 80IC : Special category States-Gross profit from trade purchases with subsidiary not different to that from third parties-No evidence of shifting expenses to subsidiary.
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