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...
Issue concerned eligibility for deduction under Section 80-IC where assessee manufactured some items listed in the Fourteenth Schedule but not those in the Thirteenth Schedule. Tribunal rejected the Revenue's contention that manufacture of Fourteenth Schedule items alone invoked Section 80-IC(2)(b); instead eligibility was determined by location in a notified eligible area and commencement of production within the specified period. Result: assessee entitled to benefit under Section 80-IC(2)(a)(ii) on satisfying location and commencement criteria, not merely by producing certain Fourteenth Schedule goods.
Issue concerned eligibility for deduction under Section 80-IC where assessee manufactured some items listed in the Fourteenth Schedule but not those in the Thirteenth Schedule. Tribunal rejected the Revenue's contention that manufacture of Fourteenth Schedule items alone invoked Section 80-IC(2)(b); instead eligibility was determined by location in a notified eligible area and commencement of production within the specified period. Result: assessee entitled to benefit under Section 80-IC(2)(a)(ii) on satisfying location and commencement criteria, not merely by producing certain Fourteenth Schedule goods.
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