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...
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
CIT(A)'s power u/s 251(1) restricted to subject matter assessed by AO. Addition for personal withdrawals not allowed as beyond AO's assessment. Addition for drawings from earlier year upheld as correctly reflected in capital account. Interest expenditure disallowance u/s 57(iii) deleted following coordinate bench ruling allowing deduction having nexus with dividend income. AO directed to recompute interest u/s 234B per earlier ITAT order.
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