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...
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
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