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...
Tribunal held that clause (i) of the statutory provision defining specified domestic transactions was omitted with retrospective effect, applying established precedent on retrospective omission so the provision is treated as never having existed; consequently references to the Transfer Pricing Officer and transfer pricing adjustments for the relevant assessment year were invalid and the additions based solely on that provision were directed to be deleted, leading to allowance of the appeal and removal of the contested additions.
Tribunal held that clause (i) of the statutory provision defining specified domestic transactions was omitted with retrospective effect, applying established precedent on retrospective omission so the provision is treated as never having existed; consequently references to the Transfer Pricing Officer and transfer pricing adjustments for the relevant assessment year were invalid and the additions based solely on that provision were directed to be deleted, leading to allowance of the appeal and removal of the contested additions.
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