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...
SC addressed the validity of reassessment notices where the decisive question was whether the matters related to Assessment Year 2015-16. It recorded the Revenue's concession that, for that year, reassessment notices would be time-barred in light of Rajeev Bansal; if a case falls in that year, the notices must be struck down without further adjudication. If the matters relate to any other assessment year, the assessees may raise all contentions available under the earlier order, and the High Courts must decide the cases accordingly. The impugned judgments were set aside and the matters remitted for fresh determination on that threshold issue first.
SC addressed the validity of reassessment notices where the decisive question was whether the matters related to Assessment Year 2015-16. It recorded the Revenue's concession that, for that year, reassessment notices would be time-barred in light of Rajeev Bansal; if a case falls in that year, the notices must be struck down without further adjudication. If the matters relate to any other assessment year, the assessees may raise all contentions available under the earlier order, and the High Courts must decide the cases accordingly. The impugned judgments were set aside and the matters remitted for fresh determination on that threshold issue first.
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