Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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Tribunal's conclusion that Resale Price Method (RPM) is the most appropriate method upheld. Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) had rejected RPM, citing assessee's significant Advertisement, Marketing and Promotion (AMP) expenses. However, Tribunal accepted assessee's contention that AMP expenses were not excessive and comparable to other entities. DRP's finding that assessee was not a 'routine distributor' sustainable. Revenue's challenge to Tribunal's decision dismissed, no substantial question of law arises.
Tribunal's conclusion that Resale Price Method (RPM) is the most appropriate method upheld. Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) had rejected RPM, citing assessee's significant Advertisement, Marketing and Promotion (AMP) expenses. However, Tribunal accepted assessee's contention that AMP expenses were not excessive and comparable to other entities. DRP's finding that assessee was not a 'routine distributor' sustainable. Revenue's challenge to Tribunal's decision dismissed, no substantial question of law arises.
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