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...
Dealing-error losses incurred by a share broker in client transactions are described as allowable where reassessment proceedings examined and accepted their genuineness, with no factual or legal defect identified in the appellate findings. The text also treats losses on proprietary derivative transactions as realised business losses where contract notes, transaction-wise details and contemporaneous records establish that positions were squared off during the relevant year. A corrected factual explanation, supported by evidence, prevails over an initial statement that the loss arose from an open position; compulsory cash settlement supports treatment as realised rather than notional loss.
Dealing-error losses incurred by a share broker in client transactions are described as allowable where reassessment proceedings examined and accepted their genuineness, with no factual or legal defect identified in the appellate findings. The text also treats losses on proprietary derivative transactions as realised business losses where contract notes, transaction-wise details and contemporaneous records establish that positions were squared off during the relevant year. A corrected factual explanation, supported by evidence, prevails over an initial statement that the loss arose from an open position; compulsory cash settlement supports treatment as realised rather than notional loss.
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