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...
Omission of refund-restricting Rules 89(4B) and 96(10) without any saving clause rendered the omitted provision inapplicable to pending proceedings, including matters still before the Court or the adjudicating authority and orders not yet final, because they were not transactions past and closed. Applying the earlier Gujarat HC ratio, the Court held that the order-in-original and consequential action founded on the omitted rule could not be sustained. The writ petition was allowed and the impugned order and subsequent action were quashed.
Omission of refund-restricting Rules 89(4B) and 96(10) without any saving clause rendered the omitted provision inapplicable to pending proceedings, including matters still before the Court or the adjudicating authority and orders not yet final, because they were not transactions past and closed. Applying the earlier Gujarat HC ratio, the Court held that the order-in-original and consequential action founded on the omitted rule could not be sustained. The writ petition was allowed and the impugned order and subsequent action were quashed.
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