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...
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
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