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...
Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.
Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.
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