Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
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