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...
The Tribunal restricted disallowance for a political donation deduction to the amount actually shown in the assessee's bank records, holding that a higher figure had no factual basis. It also sustained deletion of the section 69A addition for a bank time deposit, accepting that the deposit was made from disclosed salary income and that the Revenue produced no rebuttal. In respect of gratuity, leave encashment and employee allowance receipts reflected in Form 16, the Tribunal upheld the relief granted because the appellate findings were clear and remained unchallenged. The Revenue's appeal was dismissed.
The Tribunal restricted disallowance for a political donation deduction to the amount actually shown in the assessee's bank records, holding that a higher figure had no factual basis. It also sustained deletion of the section 69A addition for a bank time deposit, accepting that the deposit was made from disclosed salary income and that the Revenue produced no rebuttal. In respect of gratuity, leave encashment and employee allowance receipts reflected in Form 16, the Tribunal upheld the relief granted because the appellate findings were clear and remained unchallenged. The Revenue's appeal was dismissed.
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