Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
ITAT remanded the case to the AO for compliance with DRP's directive regarding transfer pricing adjustment. The tribunal acknowledged the DR's concession that the AO had not implemented the prescribed +/- 3% arm's length price adjustment under section 92C(1). The matter was restored to the AO's file to ensure proper application of the DRP's direction, specifically to grant the mandated transfer pricing adjustment within the statutorily defined percentage range.
ITAT remanded the case to the AO for compliance with DRP's directive regarding transfer pricing adjustment. The tribunal acknowledged the DR's concession that the AO had not implemented the prescribed +/- 3% arm's length price adjustment under section 92C(1). The matter was restored to the AO's file to ensure proper application of the DRP's direction, specifically to grant the mandated transfer pricing adjustment within the statutorily defined percentage range.
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