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...
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
Deduction under section 10A was allowed as an alternate claim even though the return had originally claimed section 10B, because Form 56F was furnished during assessment and the same units had already been allowed section 10A relief in earlier scrutiny years; in the absence of any material showing those earlier allowances were or revised, the Revenue could not deny eligibility in the later year. The Tribunal also held that the assessee failed to show that the assessment order was without jurisdiction, while the jurisdiction order under section 120 was on record, so the jurisdictional objection had no merit. The Revenue's appeal was rejected and the cross-objection was dismissed.
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