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...
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
Unsupported claims for expenditure against commission income cannot be accepted solely on the taxpayer's assertions. The text explains that, despite the absence of documentary evidence, the nature of commission activities, the taxpayer's age, cash withdrawals and the scale of commission receipts indicated that substantial expenditure on assistance, administrative needs and incidental items was inevitable. It considers an estimate of 10 per cent of gross commission receipts inadequate and prescribes allowance of expenditure at 20 per cent, requiring consequential recomputation of income.
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