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...
Cash expenditure was disallowed under section 40A(3) because the assessee failed to substantiate the claimed Rule 6DD exception with supporting ledger accounts or confirmation from the payee. The Tribunal noted that the assessee had dealt with the payee and that most payments were made in cash, so the case did not fall within the statutory exception. The disallowance was therefore upheld for the lead year and applied to the remaining assessment years, with all four appeals dismissed.
Cash expenditure was disallowed under section 40A(3) because the assessee failed to substantiate the claimed Rule 6DD exception with supporting ledger accounts or confirmation from the payee. The Tribunal noted that the assessee had dealt with the payee and that most payments were made in cash, so the case did not fall within the statutory exception. The disallowance was therefore upheld for the lead year and applied to the remaining assessment years, with all four appeals dismissed.
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