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...
Medical reimbursement and incidental travel expenses of the Chairman were held allowable as business expenditure because the board-approved service terms specifically permitted reimbursement and the business nexus was accepted. The Tribunal also set aside rejection of the Sahibabad unit's books and the estimated profit addition, finding that the assessment rested only on that unit's loss, without any specific defect in the accounts, under-reporting of receipts, or proved inflation of expenditure. The assessee's explanation that the Jaipur and Sahibabad units functioned in a combined manner was not properly considered.
Medical reimbursement and incidental travel expenses of the Chairman were held allowable as business expenditure because the board-approved service terms specifically permitted reimbursement and the business nexus was accepted. The Tribunal also set aside rejection of the Sahibabad unit's books and the estimated profit addition, finding that the assessment rested only on that unit's loss, without any specific defect in the accounts, under-reporting of receipts, or proved inflation of expenditure. The assessee's explanation that the Jaipur and Sahibabad units functioned in a combined manner was not properly considered.
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