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...
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
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