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...
Interest u/s. 244A - interest on unpaid interest - refund awarded in the rectification order u/s. 154 - The appellant contested the decision of the Commissioner of Income Tax (Appeals), emphasizing their entitlement to interest from April 1, 2017, onwards. Despite initial denial by the Assessing Officer, the Tribunal ruled in favor of the appellant, considering the rectification order and the acceptance of Minimum Alternate Tax (MAT) credit. The Tribunal's decision aligned with the appellant's interpretation of section 244A, leading to the allowance of interest from the start of the assessment year to the date of refund.
Interest u/s. 244A - interest on unpaid interest - refund awarded in the rectification order u/s. 154 - The appellant contested the decision of the Commissioner of Income Tax (Appeals), emphasizing their entitlement to interest from April 1, 2017, onwards. Despite initial denial by the Assessing Officer, the Tribunal ruled in favor of the appellant, considering the rectification order and the acceptance of Minimum Alternate Tax (MAT) credit. The Tribunal's decision aligned with the appellant's interpretation of section 244A, leading to the allowance of interest from the start of the assessment year to the date of refund.
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