Mis-declaration and Concealment: confiscation affirmed, transaction value re-determined and mandatory penalty sustained; redemption allowed on payment...
Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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