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...
Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.
Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.
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