Questão jurídica principal
Whether alleged WIR losses were sufficiently proven and deductible for profit tax purposes
Decisão extraída
The claimed WIR losses were not adequately documented and therefore could not be recognized as profit-reducing expenses.
Fundamentação extraída
The taxpayer did not comply with repeated requests to substantiate who received which WIR benefits and under what conditions. The court held that a general discount practice was insufficient without case-specific evidence; the tax authority's additions were therefore justified.