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...
Audited financial statements were treated as the reliable basis for determining closing work-in-progress where unaudited tally-generated data showed a difference caused by adding, rather than excluding, opening work-in-progress. As the audited accounts correctly reflected the brought-forward opening balance and the relevant year's closing work-in-progress, no discrepancy remained to support an addition based solely on unaudited data. The discussion states that the addition for the alleged difference in closing work-in-progress, as well as the stock-in-trade difference, was deleted.
Audited financial statements were treated as the reliable basis for determining closing work-in-progress where unaudited tally-generated data showed a difference caused by adding, rather than excluding, opening work-in-progress. As the audited accounts correctly reflected the brought-forward opening balance and the relevant year's closing work-in-progress, no discrepancy remained to support an addition based solely on unaudited data. The discussion states that the addition for the alleged difference in closing work-in-progress, as well as the stock-in-trade difference, was deleted.
Note: It is a system-generated summary and is for quick reference only.