Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
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