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...
Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT
Disallowance being 10% of expenditure - Disallowance of expenditure @ 10% of the expenditure in the instant case appears to be on the higher side since it gives a profit rate of 37.78% which is not possible in the line of business. Considering the fact that the assessee has already declared profit rate of 9.29%, the disallowance on lumpsum basis in the instant case, in our opinion, meet the ends of justice. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
