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...
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
Assessee in Default u/s 201(1) and 201(1A) - period of limitation - non deduction of TDS - the term ‘reasonable period’ in the absence of any statutory limitation cannot be accepted as a straight jacket answer. - Since the CIT(A) and ITAT have accepted the period of limitation to be four (4) years, which in the teeth of the order of the Division Bench in the case of Dr. Reddys Laboratories Limited (supra) cannot be said to be proper, legal or justified. - HC
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