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...
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
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