Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
In transfer pricing for the marketing support services segment, the ITAT excluded EDCIL (India) Ltd. because its revenue arose from dealings with Government entities and it was not a proper uncontrolled comparable; it also excluded Just Dial Ltd. for diversified operations, ownership of intangibles and absence of segmental data. Info Edge (India) Ltd. was rejected for its different service profile, multiple web-based businesses and materially different FAR profile, while India Exposition Mart Ltd. was excluded because its exhibition and conference business had a markedly different business model and employee-cost structure. The Tribunal also found that the inclusion of Cyber Media Research & Services Ltd. required verification of conflicting financial statements and remanded that issue to the TPO for fresh consideration after hearing the assessee.
In transfer pricing for the marketing support services segment, the ITAT excluded EDCIL (India) Ltd. because its revenue arose from dealings with Government entities and it was not a proper uncontrolled comparable; it also excluded Just Dial Ltd. for diversified operations, ownership of intangibles and absence of segmental data. Info Edge (India) Ltd. was rejected for its different service profile, multiple web-based businesses and materially different FAR profile, while India Exposition Mart Ltd. was excluded because its exhibition and conference business had a markedly different business model and employee-cost structure. The Tribunal also found that the inclusion of Cyber Media Research & Services Ltd. required verification of conflicting financial statements and remanded that issue to the TPO for fresh consideration after hearing the assessee.
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