Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
In wholesale trading of auto and CNG components, comparables engaged in retail and after-sales trade were found functionally dissimilar under Rule 10B(2)(d), so the disputed entities were excluded and the remaining comparable kept the margin within the acceptable range; the transfer pricing adjustments for AY 2016-17 and AY 2017-18 were deleted. For transporter payments, the claimed non-deduction of tax turned on verification of a deductee certificate that had not been examined by the lower authorities, so the disallowance issue was remanded for fresh factual verification and adjudication.
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