Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
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.
Note: It is a system-generated summary and is for quick reference only.