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...
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
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