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...
ITAT upheld depreciation on solar power plants because documentary evidence showed purchase, installation, commissioning, power generation, invoicing and receipt of sale proceeds, and the Revenue failed to discredit that material. It also rejected the section 56(2)(viib) addition, holding that the assessee could adopt the DCF valuation method and that the Assessing Officer could not substitute NAV without identifying concrete defects in the independent valuation report. Brokerage on commodity derivatives was held outside section 194H, so the section 40(a)(ia) disallowance failed. The Tribunal also sustained the section 14A disallowance only up to exempt income, and quashed the section 153D-based assessment as void because the common approval was mechanical.
ITAT upheld depreciation on solar power plants because documentary evidence showed purchase, installation, commissioning, power generation, invoicing and receipt of sale proceeds, and the Revenue failed to discredit that material. It also rejected the section 56(2)(viib) addition, holding that the assessee could adopt the DCF valuation method and that the Assessing Officer could not substitute NAV without identifying concrete defects in the independent valuation report. Brokerage on commodity derivatives was held outside section 194H, so the section 40(a)(ia) disallowance failed. The Tribunal also sustained the section 14A disallowance only up to exempt income, and quashed the section 153D-based assessment as void because the common approval was mechanical.
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