Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Disallowances u/s 40A(2)(b) - payment of commission to related party - There is no reasoning given by the ld AO that why the earlier two payment to the same party for the same services for the same accounting period on same terms and conditions are allowable, whereas the last bill itself was found to be not justified. Even at the time of disallowances, the ld AO could not show any comparable cases that the payment made to the recipient of income is unreasonable or excessive. - AT
Disallowances u/s 40A(2)(b) - payment of commission to related party - There is no reasoning given by the ld AO that why the earlier two payment to the same party for the same services for the same accounting period on same terms and conditions are allowable, whereas the last bill itself was found to be not justified. Even at the time of disallowances, the ld AO could not show any comparable cases that the payment made to the recipient of income is unreasonable or excessive. - AT
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