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...
The ITAT Delhi considered the issue of adjusting seized fixed deposits with advance tax liability. The assessee requested adjustment on 11.04.2012, before filing a belated return on 26.03.2013. The tribunal held that the request was towards self-assessment tax, irrespective of the filing date. Lower authorities overlooked this. The seized deposits were later adjusted against regular tax arrears. The tribunal directed the AO to adjust the deposits towards self-assessment tax from 11.04.2012, recalculating interest u/s 234B. Adjustments made towards regular tax should be reversed.
The ITAT Delhi considered the issue of adjusting seized fixed deposits with advance tax liability. The assessee requested adjustment on 11.04.2012, before filing a belated return on 26.03.2013. The tribunal held that the request was towards self-assessment tax, irrespective of the filing date. Lower authorities overlooked this. The seized deposits were later adjusted against regular tax arrears. The tribunal directed the AO to adjust the deposits towards self-assessment tax from 11.04.2012, recalculating interest u/s 234B. Adjustments made towards regular tax should be reversed.
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