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...
In a stay of demand matter, the HC held that the impugned order was defective because the authority fixed the amount payable and instalment schedule without discernible application of mind or a reasoned consideration of relevant factors. Referring to the CBDT stay guidelines, the Court required the stay application to be decided through a speaking order after hearing the taxpayer and considering the Supreme Court decision and the Circular. The stay order was set aside, the matter was remitted for fresh decision on merits, and recovery pursuant to the assessment order was kept in abeyance until reconsideration.
In a stay of demand matter, the HC held that the impugned order was defective because the authority fixed the amount payable and instalment schedule without discernible application of mind or a reasoned consideration of relevant factors. Referring to the CBDT stay guidelines, the Court required the stay application to be decided through a speaking order after hearing the taxpayer and considering the Supreme Court decision and the Circular. The stay order was set aside, the matter was remitted for fresh decision on merits, and recovery pursuant to the assessment order was kept in abeyance until reconsideration.
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