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...
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
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