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...
Revision u/s 263 - specified domestic transactions - effect of omission of 92BA(1) w.e.f. 1.4.2017 - the order has been revised purely on the basis that the AO has not referred to determine the ALP to the TPO - Since the provision itself stood omitted at the time when the order was passed by the Pr. CIT, the impugned order cannot be sustained, hence is hereby quashed
Revision u/s 263 - specified domestic transactions - effect of omission of 92BA(1) w.e.f. 1.4.2017 - the order has been revised purely on the basis that the AO has not referred to determine the ALP to the TPO - Since the provision itself stood omitted at the time when the order was passed by the Pr. CIT, the impugned order cannot be sustained, hence is hereby quashed
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