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...
Routine administrative and operational expenses were held allowable where the record contained no specific adverse finding that the expenditure was false or non-genuine. Disallowance based only on minimal business activity or an allegation that the entities were shell concerns was treated as perverse on the facts. The accepted genuineness of statutory and compliance-related expenses also supported the existence of normal operational costs, so the sustained disallowance of salary, rent, travelling, conveyance, telephone and similar business expenses was deleted. Interest under the consequential challenge was left to follow the main result.
Routine administrative and operational expenses were held allowable where the record contained no specific adverse finding that the expenditure was false or non-genuine. Disallowance based only on minimal business activity or an allegation that the entities were shell concerns was treated as perverse on the facts. The accepted genuineness of statutory and compliance-related expenses also supported the existence of normal operational costs, so the sustained disallowance of salary, rent, travelling, conveyance, telephone and similar business expenses was deleted. Interest under the consequential challenge was left to follow the main result.
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