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...
Existence of financial debt was affirmed where original loan was sanctioned by a bank and subsequently assigned to an ARC, reflected in the corporate debtor's audited accounts and supporting security documents, so debt and default were established for Section 7 admission. The application was within limitation as per audited acknowledgements. Procedural defects-authorization, inadequate stamping, non-service on Information Utility-were treated as curable when cured during proceedings and did not defeat admission. Electronic records and bank statements were admissible at admission stage without a Section 65B certificate, and allegations of mala fides were unsustainable on the record.
Existence of financial debt was affirmed where original loan was sanctioned by a bank and subsequently assigned to an ARC, reflected in the corporate debtor's audited accounts and supporting security documents, so debt and default were established for Section 7 admission. The application was within limitation as per audited acknowledgements. Procedural defects-authorization, inadequate stamping, non-service on Information Utility-were treated as curable when cured during proceedings and did not defeat admission. Electronic records and bank statements were admissible at admission stage without a Section 65B certificate, and allegations of mala fides were unsustainable on the record.
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