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 u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT
Penalty u/s 271G - non–maintenance of documents which the assessee is required to maintain under the statutory provisions, the Transfer Pricing Officer found it difficult to determine, the arm’s length price of the transactions with the AE - The blame for failure on the part of the TPO to determine the arm’s length price cannot be fastened with the assessee - No penalty - AT
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