Fraudulently obtained SEIS scrips cannot support customs exemption; recovery, confiscation and penalties were sustained, but employee penalty fell awa...
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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