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...
Revision u/s 263 - Deemed dividend u/s 2(22)(e) - loans received from another company - beneficial ownership - voting power fall below the specified criteria - finding of error by the CIT in the assessment order for non-invocation of section 2(22)(e) of the Act on the loans received by the assessee from MAP Ltd. palpably fails on facts recorded by the Ld.PCIT himself. - AT
Revision u/s 263 - Deemed dividend u/s 2(22)(e) - loans received from another company - beneficial ownership - voting power fall below the specified criteria - finding of error by the CIT in the assessment order for non-invocation of section 2(22)(e) of the Act on the loans received by the assessee from MAP Ltd. palpably fails on facts recorded by the Ld.PCIT himself. - AT
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