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...
An order rejecting a rebate claim and imposing penalty, based exclusively on a prior Single Judge decision, could not stand after that precedent was later set aside by a Division Bench. The High Court quashed the order because its sole foundation had disappeared, and remanded the rebate and penalty issues to the competent authority for fresh consideration in light of the Division Bench view, without expressing any opinion on merits.
An order rejecting a rebate claim and imposing penalty, based exclusively on a prior Single Judge decision, could not stand after that precedent was later set aside by a Division Bench. The High Court quashed the order because its sole foundation had disappeared, and remanded the rebate and penalty issues to the competent authority for fresh consideration in light of the Division Bench view, without expressing any opinion on merits.
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