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 of Vessel - Whether the transaction value of the vessel is to be priced mentioned in the original MOA or the reduced price indicated in the addendum? - the genuineness and the necessity of reduction in the price are required to be scrutinised very carefully - the Ld. Commissioner (Appeals) passed the impugned order only by relying the finding of lower adjudicating authority - In the instant case, the Ld. Commissioner (Appeals) has not examined the genuineness of the addendum, and has proceeded to reject the appeal of the appellant. - Matter restored back - AT
Valuation of Vessel - Whether the transaction value of the vessel is to be priced mentioned in the original MOA or the reduced price indicated in the addendum? - the genuineness and the necessity of reduction in the price are required to be scrutinised very carefully - the Ld. Commissioner (Appeals) passed the impugned order only by relying the finding of lower adjudicating authority - In the instant case, the Ld. Commissioner (Appeals) has not examined the genuineness of the addendum, and has proceeded to reject the appeal of the appellant. - Matter restored back - AT
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