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...
The Tribunal treated the scrutiny as complete scrutiny because the assessment record itself showed that the case was not confined to limited scrutiny, so the objection based on CBDT Instruction No. 20/2015 failed. It also upheld denial of section 54G relief, finding no proof of sale deeds, acquisition of new assets, or actual shifting and continuation of the industrial undertaking. The disallowance of depreciation on the block of assets and the addition linked to transfer expenses in computing short-term capital gains were sustained for want of proper written down value adjustment and documentary evidence. Relief was granted only on loss on sale of fixed assets, where the reconciliation supported the assessee's computation.
The Tribunal treated the scrutiny as complete scrutiny because the assessment record itself showed that the case was not confined to limited scrutiny, so the objection based on CBDT Instruction No. 20/2015 failed. It also upheld denial of section 54G relief, finding no proof of sale deeds, acquisition of new assets, or actual shifting and continuation of the industrial undertaking. The disallowance of depreciation on the block of assets and the addition linked to transfer expenses in computing short-term capital gains were sustained for want of proper written down value adjustment and documentary evidence. Relief was granted only on loss on sale of fixed assets, where the reconciliation supported the assessee's computation.
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