Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Post-search introduction of a research and development filter in transfer pricing comparability analysis is improper if it was not part of the initial search criteria; the filter must govern the search from the outset. Turnover is also a relevant comparability factor under TNMM because scale, market position, asset base, risk profile and economies of scale affect margins, so tested parties should be matched with enterprises operating at a broadly similar scale. On that basis, the note records exclusion of six high-turnover comparables and application of an upper turnover filter at 10 times the assessee's turnover for recomputation of arm's length price.
Post-search introduction of a research and development filter in transfer pricing comparability analysis is improper if it was not part of the initial search criteria; the filter must govern the search from the outset. Turnover is also a relevant comparability factor under TNMM because scale, market position, asset base, risk profile and economies of scale affect margins, so tested parties should be matched with enterprises operating at a broadly similar scale. On that basis, the note records exclusion of six high-turnover comparables and application of an upper turnover filter at 10 times the assessee's turnover for recomputation of arm's length price.
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