Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
ITAT held that Rule 10CA is only a computational mechanism and does not cure functional dissimilarity, scale differences or segmental deficiencies; it therefore directed exclusion of Nihilent Technologies, Tata Elxsi, Cybage Software, Infosys, Larsen & Toubro Infotech and Wipro from the comparables set. It also held that a different financial year by itself does not vitiate comparability where public-domain data can be suitably extrapolated, and directed inclusion of R Systems International on relevant-year data. The Tribunal allowed working capital adjustment based on opening and closing balances from annual reports, and held that any separate receivables adjustment must be tested after such adjustment; if still required, interest should be benchmarked at LIBOR plus 200 basis points with a 60-day credit period.
ITAT held that Rule 10CA is only a computational mechanism and does not cure functional dissimilarity, scale differences or segmental deficiencies; it therefore directed exclusion of Nihilent Technologies, Tata Elxsi, Cybage Software, Infosys, Larsen & Toubro Infotech and Wipro from the comparables set. It also held that a different financial year by itself does not vitiate comparability where public-domain data can be suitably extrapolated, and directed inclusion of R Systems International on relevant-year data. The Tribunal allowed working capital adjustment based on opening and closing balances from annual reports, and held that any separate receivables adjustment must be tested after such adjustment; if still required, interest should be benchmarked at LIBOR plus 200 basis points with a 60-day credit period.
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