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...
Commission expenditure claimed against income from other sources may be deductible where evidence establishes a direct commercial nexus between the facilitation services and the commission earned. Customer purchase orders and sales records may demonstrate the payee firm's customer relationships, overlapping product trade, infrastructure and network. Where the payment is taxed in the recipient's hands and actual payment through banking channels is undisputed, such material can support admission of additional evidence and allowance of the deduction under section 57.
Commission expenditure claimed against income from other sources may be deductible where evidence establishes a direct commercial nexus between the facilitation services and the commission earned. Customer purchase orders and sales records may demonstrate the payee firm's customer relationships, overlapping product trade, infrastructure and network. Where the payment is taxed in the recipient's hands and actual payment through banking channels is undisputed, such material can support admission of additional evidence and allowance of the deduction under section 57.
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