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 271(1)(c) - deduction of interest out of ‘income from other sources’ - The AO has admitted the claim of interest expenditure to the extent of interest income and therefore one cannot definitely say that interest expenditure was not utilized for the purpose of earning interests - The disallowance of excess expenditure over and above similar income generated, cannot invite penal action in the form of penalty
Penalty 271(1)(c) - deduction of interest out of ‘income from other sources’ - The AO has admitted the claim of interest expenditure to the extent of interest income and therefore one cannot definitely say that interest expenditure was not utilized for the purpose of earning interests - The disallowance of excess expenditure over and above similar income generated, cannot invite penal action in the form of penalty
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