Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Employee travel, hospitality, conveyance, tickets, goods, and hotel boarding expenses were held to fall within the statutory heads of fringe benefits under section 115WB(1)(b) read with section 115WB(2), so the Tribunal upheld the quantum assessment on those items. The Commissioner (Appeals) was also found to have issued only a limited consequential direction to verify tax already paid and finalise computation, not an impermissible fresh remand on merits. On penalty, the Tribunal sustained cancellation under section 271(1)(d), holding that rejection of the assessee's exclusion claim in quantum proceedings did not by itself establish inaccurate particulars, following Reliance Petroproducts.
Employee travel, hospitality, conveyance, tickets, goods, and hotel boarding expenses were held to fall within the statutory heads of fringe benefits under section 115WB(1)(b) read with section 115WB(2), so the Tribunal upheld the quantum assessment on those items. The Commissioner (Appeals) was also found to have issued only a limited consequential direction to verify tax already paid and finalise computation, not an impermissible fresh remand on merits. On penalty, the Tribunal sustained cancellation under section 271(1)(d), holding that rejection of the assessee's exclusion claim in quantum proceedings did not by itself establish inaccurate particulars, following Reliance Petroproducts.
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