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...
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
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