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2020 (10) TMI 1320 - HC - Income TaxAddition u/s 40(a)(a) - whether assessee failed to bring any evidence on record to the effect that the payments made are covered under circular No.723 of 1995 and that the non-residents ship owners/charters had filed returns u/s 172 - addition on account of interest and on account of insurance expense claimed on vehicle - addition on account of depreciation, petrol and repair expenses claimed on vehicle - disallowance of expenses being web designing and development expenses which is intangible and capital in nature - disallowance of expenses for market survey and production of commercial film for broadcasting on TV Channels - disallowance of expenses being payment made for making advertisement film which is in the nature of an intangible asset - addition made on account of under invoicing of sales made to sister concern - addition more particularly when AO has pointed out specific examples of under invoicing which has been dismissed by way of generic finding - crucial findings of AO including that sister concern operates from tax exempt jurisdiction and assessee has incurred huge advertisement expenses in foreign markets - Whether the Appellate Tribunal has erred in stating that net profit of 46.38% is not possible when the Hon'ble Karnataka HC has held in CIT vs. Vesesh Infotechnics Ltd. [2012 (9) TMI 70 - KARNATAKA HIGH COURT] that even a profitability of 94.8% is possible?” HELD THAT:- Having gone through the materials on record, we are of the view that none of the questions as proposed by the revenue could be termed as the substantial questions of law. All the questions proposed are on factual aspects of the matter.
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