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...
Deduction u/s 80IA(4) - Disallowance of project facility expenses - Revenue expenses or Capital expenditure - Appellant was engaged in infrastructure development and toll road operation - Ld. CIT(A) upheld the appellant's claim, stating that these expenses did not create capital assets and were eligible for deduction under Section 80IA(4). The tribunal, following the principle of consistency, upheld the Ld. CIT(A)'s decision, citing precedents where similar deductions were allowed, and dismissed the Revenue's appeal. Condonation of Delay: Despite the initial delay, the tri
Deduction u/s 80IA(4) - Disallowance of project facility expenses - Revenue expenses or Capital expenditure - Appellant was engaged in infrastructure development and toll road operation - Ld. CIT(A) upheld the appellant's claim, stating that these expenses did not create capital assets and were eligible for deduction under Section 80IA(4). The tribunal, following the principle of consistency, upheld the Ld. CIT(A)'s decision, citing precedents where similar deductions were allowed, and dismissed the Revenue's appeal. Condonation of Delay: Despite the initial delay, the tri
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