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...
Bank account credits were held to originate from a third party and the account functioned as a conduit; therefore the credited sums were not treated as the assessee's unexplained income. The Tribunal relied on bank statements, deposit-withdrawal patterns and admissions to conclude the assessee permitted use of his account for Shree Impex, with a different principal beneficiary. Because the assessee facilitated transactions and obtained a limited benefit, the Tribunal treated the correct tax consequence as assessable commission income and directed assessment of commission on the turnover routed through the account, applying the same reasoning to other identical assessment years.
Bank account credits were held to originate from a third party and the account functioned as a conduit; therefore the credited sums were not treated as the assessee's unexplained income. The Tribunal relied on bank statements, deposit-withdrawal patterns and admissions to conclude the assessee permitted use of his account for Shree Impex, with a different principal beneficiary. Because the assessee facilitated transactions and obtained a limited benefit, the Tribunal treated the correct tax consequence as assessable commission income and directed assessment of commission on the turnover routed through the account, applying the same reasoning to other identical assessment years.
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