Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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Turnover is a relevant comparability filter in transfer pricing for software development services, and applying a ten-times range on both ends for selecting comparables was upheld. Several entities were excluded as functionally dissimilar because they were software product or diversified companies, or because earlier coordinate bench views supported exclusion and no contrary material was shown. Evoke Technologies Ltd. was retained as a comparable since audited records enabled identification of Indian operating revenue and computation of the profit level indicator after excluding overseas branch revenue. The Tribunal also held that benchmarking does not fail merely because only two comparables remain, and dismissed the Revenue's appeal.
Turnover is a relevant comparability filter in transfer pricing for software development services, and applying a ten-times range on both ends for selecting comparables was upheld. Several entities were excluded as functionally dissimilar because they were software product or diversified companies, or because earlier coordinate bench views supported exclusion and no contrary material was shown. Evoke Technologies Ltd. was retained as a comparable since audited records enabled identification of Indian operating revenue and computation of the profit level indicator after excluding overseas branch revenue. The Tribunal also held that benchmarking does not fail merely because only two comparables remain, and dismissed the Revenue's appeal.
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