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...
Scope of the "Point of difference" - Divergent views of the members of tribunal - matter referred to third member - appellant sight that more points to be included in the reference made to third member - this `Tribunal’ is of the earnest opinion that the said `impugned order’ cannot be termed by no stretch of imagination as `an Order’, in the teeth of culling out of `the point of difference’ (between the `Hon’ble Two Members of the Tribunal’) and formulating the same, is just a `Ministerial Act’ (`on Administrative Side’) of the `Tribunal’, without an entry upon any `Adjudicatory Process’. - No appeal is maintainable against the same - AT
Scope of the "Point of difference" - Divergent views of the members of tribunal - matter referred to third member - appellant sight that more points to be included in the reference made to third member - this `Tribunal’ is of the earnest opinion that the said `impugned order’ cannot be termed by no stretch of imagination as `an Order’, in the teeth of culling out of `the point of difference’ (between the `Hon’ble Two Members of the Tribunal’) and formulating the same, is just a `Ministerial Act’ (`on Administrative Side’) of the `Tribunal’, without an entry upon any `Adjudicatory Process’. - No appeal is maintainable against the same - AT
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