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...
Unpaid bonus provisions are disallowable in the year of claim where payment conditions are not met, but the same income cannot be taxed again when an excess provision is reversed and offered in a later year; any resulting double taxation must be avoided through verification and reduction. Provisions made by a co-operative bank against standard assets were treated as deductible, resulting in deletion of the related disallowances. A separate disallowance of income-tax provision was deleted because the amount had already been added back, preventing double addition. Ex gratia employee incentives were treated as salary or incentive payments allowable in the year of payment. Carry-forward depreciation was directed to be recomputed.
Unpaid bonus provisions are disallowable in the year of claim where payment conditions are not met, but the same income cannot be taxed again when an excess provision is reversed and offered in a later year; any resulting double taxation must be avoided through verification and reduction. Provisions made by a co-operative bank against standard assets were treated as deductible, resulting in deletion of the related disallowances. A separate disallowance of income-tax provision was deleted because the amount had already been added back, preventing double addition. Ex gratia employee incentives were treated as salary or incentive payments allowable in the year of payment. Carry-forward depreciation was directed to be recomputed.
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