Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Disallowance of commission expenses paid by the assessee to its related concern - the fact that the assessee deducted tax at source and both the companies are falling under maximum marginal rate of tax, does not satisfy the requirement of reasonableness of expenditure qua the services alleged to be received by the assessee. All the above aspects were neither examined by the AO nor by the CIT(A) and appeal filed by the assessee was allowed vide impugned order without even calling for any remand report, in this regard, from the AO. - Matter restored back - AT
Disallowance of commission expenses paid by the assessee to its related concern - the fact that the assessee deducted tax at source and both the companies are falling under maximum marginal rate of tax, does not satisfy the requirement of reasonableness of expenditure qua the services alleged to be received by the assessee. All the above aspects were neither examined by the AO nor by the CIT(A) and appeal filed by the assessee was allowed vide impugned order without even calling for any remand report, in this regard, from the AO. - Matter restored back - AT
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