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...
Genuine share trading transactions executed through a registered broker on the stock exchange, reflected in DEMAT and trading records, and settled through banking channels were held to support allowability of the resulting business loss. The Tribunal held that the loss could not be disallowed merely because the Revenue considered the trades commercially imprudent or compared them with book value, in the absence of material showing artificial loss creation, sham trades, or price manipulation. It further held that SEBI proceedings against company promoters and penny-stock rulings on bogus exempt gains were inapplicable where the assessee's own transactions were genuine trading transactions, and the addition was deleted.
Genuine share trading transactions executed through a registered broker on the stock exchange, reflected in DEMAT and trading records, and settled through banking channels were held to support allowability of the resulting business loss. The Tribunal held that the loss could not be disallowed merely because the Revenue considered the trades commercially imprudent or compared them with book value, in the absence of material showing artificial loss creation, sham trades, or price manipulation. It further held that SEBI proceedings against company promoters and penny-stock rulings on bogus exempt gains were inapplicable where the assessee's own transactions were genuine trading transactions, and the addition was deleted.
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