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...
MAT - inclusion of "transition amount" u/s. 115JB (2C) while computing the book profit - Zero Coupon OFCDs - There will not be any transition amount which requires any adjustment in the book profit as per section 115JB (2C) of the Act. It is important to note that as discussed herein above, the capital liability and financial liability are two different concepts and Ld Pr. CIT has confused with the above two concepts and treated the capital liability as disclosed by the assessee as part of Composite Income in the schedule to the Other Equity. - no adjustment is required in the book profit u/s 115 JB (2C) - AT
MAT - inclusion of "transition amount" u/s. 115JB (2C) while computing the book profit - Zero Coupon OFCDs - There will not be any transition amount which requires any adjustment in the book profit as per section 115JB (2C) of the Act. It is important to note that as discussed herein above, the capital liability and financial liability are two different concepts and Ld Pr. CIT has confused with the above two concepts and treated the capital liability as disclosed by the assessee as part of Composite Income in the schedule to the Other Equity. - no adjustment is required in the book profit u/s 115 JB (2C) - AT
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