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 - Addition u/s 69A of the Act read with section 115BBE - the findings and directions of the ld Pr CIT contained are not borne out of material available on record and secondly, the such findings have been recorded without providing any opportunity of being heard to the assessee, therefore, such findings are hereby set-aside and to that extent, the order of the Pr CIT stands modified. - AT
Revision u/s 263 - Addition u/s 69A of the Act read with section 115BBE - the findings and directions of the ld Pr CIT contained are not borne out of material available on record and secondly, the such findings have been recorded without providing any opportunity of being heard to the assessee, therefore, such findings are hereby set-aside and to that extent, the order of the Pr CIT stands modified. - AT
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