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...
For sales before 1 June 2003, the tax-collection-at-source entry for alcoholic liquor for human consumption expressly excluded Indian Made Foreign Liquor (IMFL). As IMFL was undefined in the Income-tax Act, its meaning was considered in commercial and statutory context; the Tribunal's classification of beer as IMFL was treated as a reasonable view. State excise classifications could assist but could not control the Income-tax Act. The later deletion of the IMFL exclusion broadened the entry prospectively. Consequently, beer sales fell outside the earlier entry, so no tax-collection obligation, default liability, or consequential interest arose.
For sales before 1 June 2003, the tax-collection-at-source entry for alcoholic liquor for human consumption expressly excluded Indian Made Foreign Liquor (IMFL). As IMFL was undefined in the Income-tax Act, its meaning was considered in commercial and statutory context; the Tribunal's classification of beer as IMFL was treated as a reasonable view. State excise classifications could assist but could not control the Income-tax Act. The later deletion of the IMFL exclusion broadened the entry prospectively. Consequently, beer sales fell outside the earlier entry, so no tax-collection obligation, default liability, or consequential interest arose.
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