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...
DSIR-approved in-house R&D deduction cannot be disallowed by the AO or DRP on the basis of survey statements once the prescribed authority has quantified the eligible expenditure; later survey findings do not unsettle earlier certified claims. Where procurement commission had already been benchmarked in transfer pricing proceedings, a further disallowance under the normal provisions was treated as impermissible double disallowance, absent evidence that the payment was sham. On APA-consistent transactions, the raw material purchase adjustment was restricted and the corporate guarantee adjustment was deleted or capped. Litigation provision, Chapter VI-A deduction and TDS credit issues were remitted for verification, with interest consequential and penalty premature.
DSIR-approved in-house R&D deduction cannot be disallowed by the AO or DRP on the basis of survey statements once the prescribed authority has quantified the eligible expenditure; later survey findings do not unsettle earlier certified claims. Where procurement commission had already been benchmarked in transfer pricing proceedings, a further disallowance under the normal provisions was treated as impermissible double disallowance, absent evidence that the payment was sham. On APA-consistent transactions, the raw material purchase adjustment was restricted and the corporate guarantee adjustment was deleted or capped. Litigation provision, Chapter VI-A deduction and TDS credit issues were remitted for verification, with interest consequential and penalty premature.
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