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...
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
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