Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Ad hoc disallowance of vehicle depreciation cannot stand without adverse material or a factual basis showing personal use or defective record-keeping; where the assessee asserted log books and audit controls and the Revenue produced no specific rebuttal, the disallowance was treated as arbitrary and deleted. Donations for festivities were held allowable where CBDT circulars covered such payments, and those circulars were binding on the Revenue, so the addition was deleted. For fine and penalty expenditure under section 37(1), the record lacked sufficient factual clarity, and the remand to the Assessing Officer for verification was upheld, leaving that issue open on merits.
Ad hoc disallowance of vehicle depreciation cannot stand without adverse material or a factual basis showing personal use or defective record-keeping; where the assessee asserted log books and audit controls and the Revenue produced no specific rebuttal, the disallowance was treated as arbitrary and deleted. Donations for festivities were held allowable where CBDT circulars covered such payments, and those circulars were binding on the Revenue, so the addition was deleted. For fine and penalty expenditure under section 37(1), the record lacked sufficient factual clarity, and the remand to the Assessing Officer for verification was upheld, leaving that issue open on merits.
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