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...
The Supreme Court held that amounts repayable after a specified period, with promised quarterly interest, fell within the wide definition of "deposit" under Section 2(c) of the MPID Act. It further held that Section 2(d) uses expansive language and includes private persons receiving such deposits, so respondent Nos. 2 to 6 were financial establishments for MPID Act purposes. Prior failure of IPC-based proceedings and the civil character of the transaction did not bar recourse under Section 3, because the MPID Act provides an independent statutory remedy operating in a distinct field. The High Court's contrary view was set aside.
The Supreme Court held that amounts repayable after a specified period, with promised quarterly interest, fell within the wide definition of "deposit" under Section 2(c) of the MPID Act. It further held that Section 2(d) uses expansive language and includes private persons receiving such deposits, so respondent Nos. 2 to 6 were financial establishments for MPID Act purposes. Prior failure of IPC-based proceedings and the civil character of the transaction did not bar recourse under Section 3, because the MPID Act provides an independent statutory remedy operating in a distinct field. The High Court's contrary view was set aside.
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