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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Additions based only on an impounded diary and survey disclosure were deleted because the Assessing Officer had no corroborative material, and the concluded land transaction made the alleged later cash payment improbable; the retraction was accepted and no substantial question of law arose. On the separate issue of unexplained investment, cash receipts recorded in the same diary were telescoped against the investment already offered to tax, preventing double taxation; this too was treated as a factual finding with no substantial question of law. The Revenue's challenges therefore failed and its appeals were dismissed.
Additions based only on an impounded diary and survey disclosure were deleted because the Assessing Officer had no corroborative material, and the concluded land transaction made the alleged later cash payment improbable; the retraction was accepted and no substantial question of law arose. On the separate issue of unexplained investment, cash receipts recorded in the same diary were telescoped against the investment already offered to tax, preventing double taxation; this too was treated as a factual finding with no substantial question of law. The Revenue's challenges therefore failed and its appeals were dismissed.
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