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...
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
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