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...
Interest differential credited to statutory development funds was treated as diverted at source under the scheme directions, so it was not taxable in the assessee's hands; the Tribunal followed its earlier orders in the assessee's own case and noted that the assessee acted only as a nodal or implementing agency. Promotional and developmental expenditure was also allowed because the assessee had been notified from financial year 2012-13, applicable from assessment year 2013-14, so the basis of disallowance failed. The Revenue's appeal was dismissed and the appellate order was upheld in full.
Interest differential credited to statutory development funds was treated as diverted at source under the scheme directions, so it was not taxable in the assessee's hands; the Tribunal followed its earlier orders in the assessee's own case and noted that the assessee acted only as a nodal or implementing agency. Promotional and developmental expenditure was also allowed because the assessee had been notified from financial year 2012-13, applicable from assessment year 2013-14, so the basis of disallowance failed. The Revenue's appeal was dismissed and the appellate order was upheld in full.
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