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...
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
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