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...
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
Interest under section 234B was held not leviable where the assessee computed and paid advance tax in accordance with the law then in force, and the shortfall arose only because ICDS applicability was later deferred by a retrospective legal change. The Tribunal held that default in advance tax must be tested on the basis of the law existing when the assessee was required to estimate current income and pay advance tax. Since the later change was not foreseeable at the relevant time, the assessee could not be treated as in default, and the interest demand was deleted.
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