Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
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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