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...
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
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