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...
Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).
Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).
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