Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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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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