https://www.taxtmi.com/caselaws?id=339974 Disallowance under section 40(a)(i) required verification of whether the resident payees had already disclosed the receipts and discharged tax, so the matter was remitted for fresh consideration. Payments to agents of non-resident ship owners or charterers also had to be tested against the underlying shipping arrangement and the possible application of section 172, and this issue was likewise sent back for reconsideration. In transfer pricing, a persistent loss-maker was rightly rejected as a comparable, while companies with a different accounting year could be re-evaluated after recasting and verification. Segmental data supported the inclusion of NR International Ltd. and Natura Hue Chem Ltd. as comparables. en-us Fri, 03 Mar 2017 00:00:00 +0530 Thu, 09 Mar 2017 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339974 Disallowance under section 40(a)(i) required verification of whether the resident payees had already disclosed the receipts and discharged tax, so the matter was remitted for fresh consideration. Payments to agents of non-resident ship owners or charterers also had to be tested against the underlying shipping arrangement and the possible application of section 172, and this issue was likewise sent back for reconsideration. In transfer pricing, a persistent loss-maker was rightly rejected as a comparable, while companies with a different accounting year could be re-evaluated after recasting and verification. Segmental data supported the inclusion of NR International Ltd. and Natura Hue Chem Ltd. as comparables. Case-Laws Income Tax Fri, 03 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339974