Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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