Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
Revenue-sharing under a participative railway infrastructure arrangement was treated as a joint venture-like model, not as business support service, because freight collections were shared as a return on capital investment with profit and not as consideration for any identified service. The text notes that there was no service provider-recipient relationship or direct quid pro quo, so the demand on that footing was not sustainable. It also records that a bona fide belief, supported by prior Tribunal rulings on similar arrangements, defeated suppression, making the extended limitation period unavailable.
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