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 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
Revision u/s 263 - Taxability of income disclosed in survey proceedings u/s 133A at Higher Rate of tax u/s 115BBE - ITAT quashed order treating the undisclosed income as business income and not under the higher tax rate provisions of Section 115BBE. - The High court agreed with the Tribunal's finding that sufficient inquiry was made and the income was rightly treated as business income, thus, upholding the Tribunal's decision.
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