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 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
Revision u/s 263 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
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