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...
Audited financial statements separately disclosed agricultural income and non-agricultural income, with the non-agricultural component offered to tax and the agricultural income claimed exempt. The Tribunal held that the first appellate authority proceeded on an incorrect factual premise in stating that no bifurcation existed. Because the audited statements were before the assessing and appellate authorities and the income and expenditure figures were not disputed, the claim of exempt agricultural income was accepted. The addition made by treating the agricultural income as business income was deleted.
Audited financial statements separately disclosed agricultural income and non-agricultural income, with the non-agricultural component offered to tax and the agricultural income claimed exempt. The Tribunal held that the first appellate authority proceeded on an incorrect factual premise in stating that no bifurcation existed. Because the audited statements were before the assessing and appellate authorities and the income and expenditure figures were not disputed, the claim of exempt agricultural income was accepted. The addition made by treating the agricultural income as business income was deleted.
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