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...
Disallowance of pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.
Disallowance of pro-rata premium on Foreign Currency Convertible Bonds (FCCB) claimed as expenditure by assessee under Tonnage Tax Scheme. Law prohibits deduction of any expenditure against Tonnage income once specified provisions accepted. Assessee's argument of availability of free funds rejected as not raised before lower authority. Depreciation on UPS allowed at 60% rate as per Ushodaya case, overruling 15% rate. ITAT refers to Appellate Tribunal.
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