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...
Broken period amount received on transfer of non-convertible debentures retained the character of interest, even though it was paid by the purchaser rather than the issuer, because the NCDs were transferred on a cum-interest basis and the amount represented accrued return for the intervening period. The Tribunal held that the source of payment did not change the intrinsic character of the receipt. The amount was therefore assessable as interest under the head 'Income from Other Sources', and the assessee's appeal failed.
Broken period amount received on transfer of non-convertible debentures retained the character of interest, even though it was paid by the purchaser rather than the issuer, because the NCDs were transferred on a cum-interest basis and the amount represented accrued return for the intervening period. The Tribunal held that the source of payment did not change the intrinsic character of the receipt. The amount was therefore assessable as interest under the head 'Income from Other Sources', and the assessee's appeal failed.
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