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...
Transfer of Jurisdiction u/s 127 - File were transferred from Kolkata's jurisdiction to Chennai - The Revenue's argument that the PAN and files were still within Kolkata's jurisdiction was dismissed, as the transfer of jurisdiction was a consequential proceeding. The Tribunal's decision was upheld, and the appeal failed against the Revenue.
Transfer of Jurisdiction u/s 127 - File were transferred from Kolkata's jurisdiction to Chennai - The Revenue's argument that the PAN and files were still within Kolkata's jurisdiction was dismissed, as the transfer of jurisdiction was a consequential proceeding. The Tribunal's decision was upheld, and the appeal failed against the Revenue.
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