Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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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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