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...
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Consistency in the assessee's own case governed the treatment of alleged notional interest on advances to a subsidiary: the addition was deleted because the issue had already been decided in the assessee's favour on identical facts, and the Revenue showed no distinguishing fact or change in law for the year. Pendency of earlier Revenue appeals before the High Court did not, by itself, justify departure from the settled view. The note records that the notional interest addition was therefore upheld as deleted for the relevant year.
Consistency in the assessee's own case governed the treatment of alleged notional interest on advances to a subsidiary: the addition was deleted because the issue had already been decided in the assessee's favour on identical facts, and the Revenue showed no distinguishing fact or change in law for the year. Pendency of earlier Revenue appeals before the High Court did not, by itself, justify departure from the settled view. The note records that the notional interest addition was therefore upheld as deleted for the relevant year.
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