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...
Refund of accumulated credit - ascertainment of eligible refund under Rule 5 - In both the numerator and denominator, the amount of export turnover have to be considered (i.e. same figure ) when there is no domestic services rendered by the assessee appellant inasmuch as the “value of all other services” would be ‘NIL’ in the given case. There is no reason to consider the aggregate of the value of export turnover payment of which has been received and those for which payment has not been received, since not required in the prescribed formula - AT
Refund of accumulated credit - ascertainment of eligible refund under Rule 5 - In both the numerator and denominator, the amount of export turnover have to be considered (i.e. same figure ) when there is no domestic services rendered by the assessee appellant inasmuch as the “value of all other services” would be ‘NIL’ in the given case. There is no reason to consider the aggregate of the value of export turnover payment of which has been received and those for which payment has not been received, since not required in the prescribed formula - AT
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