Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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