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...
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
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