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...
Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee's alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.
Delayed filing of Form No. 67 did not, by itself, justify denial of foreign tax credit; the Tribunal treated the Rule 128 timeline as a directory procedural requirement and directed allowance of the claim subject to verification. The assessee's alternative plea that ESOP perquisites were not taxable in India because of his residential status was not examined on the additional passport and travel material; that issue was remitted for fresh adjudication after factual verification.
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