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...
Professional fees paid for services linked to imports from OFAC-restricted Iranian-origin goods were held allowable under section 37(1) because the assessee proved the recipient's identity, genuineness of payment, and banking trail, while the payee confirmed the transactions and disclosed them in its tax records. The Tribunal accepted that the services addressed abnormal remittance delays caused by OFAC-related banking scrutiny, and that comparative material showed improved payment cycles, turnover, and profits after the services were used. Revenue's disallowance failed because it relied on suspicion without independent enquiry or evidence that the services were nonexistent or that payments were returned.
Professional fees paid for services linked to imports from OFAC-restricted Iranian-origin goods were held allowable under section 37(1) because the assessee proved the recipient's identity, genuineness of payment, and banking trail, while the payee confirmed the transactions and disclosed them in its tax records. The Tribunal accepted that the services addressed abnormal remittance delays caused by OFAC-related banking scrutiny, and that comparative material showed improved payment cycles, turnover, and profits after the services were used. Revenue's disallowance failed because it relied on suspicion without independent enquiry or evidence that the services were nonexistent or that payments were returned.
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