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 case involves a dispute regarding clandestine removal of goods by an Appellant company. The Appellate Tribunal held that the allegation of clandestine removal and suppression of facts failed as no evidence of unaccounted purchases or sales was presented. The Tribunal found that the determination of suppressed quantities based on maximum installed capacity was unsubstantiated. The Tribunal also noted that the Department's withdrawal of a previous letter indicated a lack of clarity regarding the recording of goods. The Tribunal pointed out that normal industry factors were ignored in determining maximum capacity. Ultimately, the impugned Order was set aside, and the appeal was allowed.
The case involves a dispute regarding clandestine removal of goods by an Appellant company. The Appellate Tribunal held that the allegation of clandestine removal and suppression of facts failed as no evidence of unaccounted purchases or sales was presented. The Tribunal found that the determination of suppressed quantities based on maximum installed capacity was unsubstantiated. The Tribunal also noted that the Department's withdrawal of a previous letter indicated a lack of clarity regarding the recording of goods. The Tribunal pointed out that normal industry factors were ignored in determining maximum capacity. Ultimately, the impugned Order was set aside, and the appeal was allowed.
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