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 ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
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