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...
Penalty proceedings for alleged under-reporting or misreporting of income failed where the exact statutory limb was not specified. The ITAT treated the sweeping invocation of both limbs as non-application of mind and held the penalty unsustainable under the relevant provision. On identical facts, penalties for AY 2020-21 and AY 2019-20 were deleted, and deletion for AY 2018-19 was affirmed.
Penalty proceedings for alleged under-reporting or misreporting of income failed where the exact statutory limb was not specified. The ITAT treated the sweeping invocation of both limbs as non-application of mind and held the penalty unsustainable under the relevant provision. On identical facts, penalties for AY 2020-21 and AY 2019-20 were deleted, and deletion for AY 2018-19 was affirmed.
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