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...
Advances written off were held deductible only if the assessee proves they were advanced for business purposes, became irrecoverable, and satisfy the statutory conditions for bad debt or business loss; because complete particulars were not furnished, the matter was remanded for fresh verification. A claim for correct MAT credit carry forward was admitted in principle before the appellate authority, since a new claim may be raised absent a statutory bar, but computation was sent back for scrutiny. An appeal against a rectification order passed in an assessment made under DRP directions was held maintainable. The rectification dispute was also remitted for fresh consideration because proper opportunity was not given and additional evidence required examination.
Advances written off were held deductible only if the assessee proves they were advanced for business purposes, became irrecoverable, and satisfy the statutory conditions for bad debt or business loss; because complete particulars were not furnished, the matter was remanded for fresh verification. A claim for correct MAT credit carry forward was admitted in principle before the appellate authority, since a new claim may be raised absent a statutory bar, but computation was sent back for scrutiny. An appeal against a rectification order passed in an assessment made under DRP directions was held maintainable. The rectification dispute was also remitted for fresh consideration because proper opportunity was not given and additional evidence required examination.
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