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...
Penalty for cash loan acceptance and repayment is not automatic where a bona fide reasonable cause exists. The notes state that emergency funding needs justified genuine cash loans because the lenders' identity and creditworthiness were undisputed, with no finding of unaccounted income or tax evasion. In the absence of deliberate disregard of law, contumacious conduct, or intent to defeat the restriction, the acceptance penalty was deleted. The same accepted explanation and reasonable-cause protection applied to cash repayment of those loans, resulting in deletion of the repayment penalty as well.
Penalty for cash loan acceptance and repayment is not automatic where a bona fide reasonable cause exists. The notes state that emergency funding needs justified genuine cash loans because the lenders' identity and creditworthiness were undisputed, with no finding of unaccounted income or tax evasion. In the absence of deliberate disregard of law, contumacious conduct, or intent to defeat the restriction, the acceptance penalty was deleted. The same accepted explanation and reasonable-cause protection applied to cash repayment of those loans, resulting in deletion of the repayment penalty as well.
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