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...
Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
Interest on delayed statutory payments was held allowable as compensatory in nature, so disallowance of interest on delayed PF, ESI and service tax payments was not sustained. Cash payment disallowance under section 40A(3) failed because the assessee produced books, labour records and attendance material, and no specific payment to a single person in a day above the statutory threshold was identified. Addition under section 68 was deleted because the receipts were found to be business advances from customers against supply of goods, not unexplained cash credits. The Revenue's challenge was dismissed and the appellate order was upheld.
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