Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
Predominant trading activity in the healthcare segment justified excluding two manufacturing comparables, because the assessee's functional profile, assets employed and risks assumed differed materially from manufacturers; that exclusion was upheld for both assessment years on the same facts. For intra-group IT support services, maintenance-related charges for an already implemented IT infrastructure were accepted on the same footing as the earlier year, so the arm's length price could not be determined at nil and the transfer pricing adjustment was deleted.
Predominant trading activity in the healthcare segment justified excluding two manufacturing comparables, because the assessee's functional profile, assets employed and risks assumed differed materially from manufacturers; that exclusion was upheld for both assessment years on the same facts. For intra-group IT support services, maintenance-related charges for an already implemented IT infrastructure were accepted on the same footing as the earlier year, so the arm's length price could not be determined at nil and the transfer pricing adjustment was deleted.
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