Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Disallowance of export commission paid by the assessee - allowable business expenses or not? - Despite the substantial increase in commission compared to the preceding year, there was no allegation of the commission being paid to a related party or being bogus. The ITAT recognized the challenging market situation in the export industry, which warranted higher commission payments due to extra efforts by commission agents. The Tribunal found that the expenditure was incurred wholly and exclusively for business purposes, with no contradictory evidence on record. - As a result, the ITAT allowed the appeal by the assessee
Disallowance of export commission paid by the assessee - allowable business expenses or not? - Despite the substantial increase in commission compared to the preceding year, there was no allegation of the commission being paid to a related party or being bogus. The ITAT recognized the challenging market situation in the export industry, which warranted higher commission payments due to extra efforts by commission agents. The Tribunal found that the expenditure was incurred wholly and exclusively for business purposes, with no contradictory evidence on record. - As a result, the ITAT allowed the appeal by the assessee
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