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...
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
Rejection of books of account in derivative trading was unjustified where the books were audited and detailed trading statements were available; applying a fixed 12% of turnover as an arbitrary profit estimate lacked a reasonable basis. Because the assessing officer did not place material to support either the rejection of accounts or the turnover based estimation, the appellate deletion of the estimated business income was affirmed and the revenue's appeal was dismissed.
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