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...
Valuation - treatment of the trade discount as additional consideration - The Tribunal noted that the transaction value should be determined based on commercial considerations, especially when the buyer and seller are not related. - The Tribunal distinguished the case from previous decisions involving oil marketing companies (OMCs) and upheld the appellant's contention that the transactions with OMCs were on a principal-to-principal basis. It was observed that there was no evidence of a service contract between the appellant and OMCs.
Valuation - treatment of the trade discount as additional consideration - The Tribunal noted that the transaction value should be determined based on commercial considerations, especially when the buyer and seller are not related. - The Tribunal distinguished the case from previous decisions involving oil marketing companies (OMCs) and upheld the appellant's contention that the transactions with OMCs were on a principal-to-principal basis. It was observed that there was no evidence of a service contract between the appellant and OMCs.
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