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 final assessment order that ignored the partial relief granted by the DRP and repeated the draft additions was invalid because the assessment had to be passed in conformity with the DRP directions. The Tribunal treated the non-compliance as a violation of the statutory mandate and, following binding precedent, quashed the order; the remaining grounds were therefore academic.
A final assessment order that ignored the partial relief granted by the DRP and repeated the draft additions was invalid because the assessment had to be passed in conformity with the DRP directions. The Tribunal treated the non-compliance as a violation of the statutory mandate and, following binding precedent, quashed the order; the remaining grounds were therefore academic.
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