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...
A single show cause notice could not be enforced against both the former proprietorship and the later partnership firm for the post-conversion period, because the remand order required separate notices and no fresh notice to the partnership firm was shown; the later demand was therefore set aside. In works contract matters, a community hall intended for paid use and fruit and vegetable stalls were treated as having commercial character, so the claimed non-commercial exemption failed, while boundary walls, a public sports complex and related landscaping were held non-commercial on the dominant-use test. TDS and refundable security deposits were excluded from taxable value. Payment already made for EWS housing was left open to verification.
A single show cause notice could not be enforced against both the former proprietorship and the later partnership firm for the post-conversion period, because the remand order required separate notices and no fresh notice to the partnership firm was shown; the later demand was therefore set aside. In works contract matters, a community hall intended for paid use and fruit and vegetable stalls were treated as having commercial character, so the claimed non-commercial exemption failed, while boundary walls, a public sports complex and related landscaping were held non-commercial on the dominant-use test. TDS and refundable security deposits were excluded from taxable value. Payment already made for EWS housing was left open to verification.
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