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...
Valuation - contemporaneous import - import of betel nuts made by the Appellant - rejection of transaction value - In view of the non-availability of evidence of identical or similar goods of same quantity and at same commercial level, the suspicion casted by the Original Authority, leading to the rejection of transaction value is also incorrect. Therefore rejection of transaction value, even at the first place, is misplaced. - AT
Valuation - contemporaneous import - import of betel nuts made by the Appellant - rejection of transaction value - In view of the non-availability of evidence of identical or similar goods of same quantity and at same commercial level, the suspicion casted by the Original Authority, leading to the rejection of transaction value is also incorrect. Therefore rejection of transaction value, even at the first place, is misplaced. - AT
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