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...
The tribunal affirmed that cash deposits in the assessee's proprietorship bank accounts during the demonetisation period were treated as unexplained income where the assessee failed to respond to statutory notices or furnish any explanation or documents; on the basis of bank data the deposits were attributed to the assessee and taxed accordingly. Separately, the claimed current-year loss set off was disallowed because the assessee did not produce supporting details before the tax authorities or on appeal, leaving the claim unsubstantiated. All grounds of appeal were dismissed for lack of material and failure to furnish explanations or appear.
The tribunal affirmed that cash deposits in the assessee's proprietorship bank accounts during the demonetisation period were treated as unexplained income where the assessee failed to respond to statutory notices or furnish any explanation or documents; on the basis of bank data the deposits were attributed to the assessee and taxed accordingly. Separately, the claimed current-year loss set off was disallowed because the assessee did not produce supporting details before the tax authorities or on appeal, leaving the claim unsubstantiated. All grounds of appeal were dismissed for lack of material and failure to furnish explanations or appear.
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