Disallowance of Loss on Tools & Dies Sales Based on Surmises Unsustainable: Delhi HC

PCIT Vs G-Tekt India Pvt Ltd (Delhi High Court)

Delhi High Court held that AO cannot supplant its view as to the commercial expediency of the transactions. Accordingly, disallowance of loss incurred on purchase and sale of tools and dies based on surmises and assumptions not sustainable.

Facts- The Assessee is engaged in the business of manufacturing and sale of automotive parts and components. The Assessee had filed its return in respect of AY 2014-15 declaring a loss of ₹28,09,72,605/-. AO had found that the loss as declared had arisen on account of tran

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