Case Law Details
SI Group India P. Ltd Vs ACIT (ITAT Mumbai)
ITAT Mumbai held that catalyst expenditure merely used as consumables is revenue expenditure. Accordingly, the same is allowable as deduction.
Facts-
The return of income of the assessee was picked up for scrutiny. As assessee has entered into international transactions reference was made to the Ld. Transfer Pricing Officer to determine the Arm’s Length Price of international transactions.
TPO passed order u/s. 92CA (3) of the Act and an adjustment of ₹45,78,73,000/- was made. Assessee filed objection before the DRP- 2, Mumbai wherein the transfer pricing adjustment was modified to ₹10,97,84,000/-. Consequent to that, assessment order u/s. 143(3) r.w.s. 144C (13) was passed determining total income of the assessee at loss of ₹ 14,28,98,820. AO made disallowance of expenditure incurred u/s 35(1)(vi); disallowance u/s 14A against exempt income earned; addition towards certain sundry balances; addition towards difference and mismatch in Form No. 26AS.
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