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...
Penalty under Sections 112(a) and 112(b) could not be sustained because the show-cause notice did not propose those penalties; the Tribunal set them aside for want of notice. Section 114AA was held to cover any knowing or intentional use of a false or incorrect declaration, statement or document in transactions under the Act, including import matters; the Tribunal therefore confirmed the penalty under that provision.
Penalty under Sections 112(a) and 112(b) could not be sustained because the show-cause notice did not propose those penalties; the Tribunal set them aside for want of notice. Section 114AA was held to cover any knowing or intentional use of a false or incorrect declaration, statement or document in transactions under the Act, including import matters; the Tribunal therefore confirmed the penalty under that provision.
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