Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Routine captive HR consultancy services of a low-risk service provider were benchmarked under TNMM on a cost-plus basis, and the Tribunal upheld the assessee's comparables on FAR analysis. It held that the TPO's substituted companies, engaged in IT consulting, software development, cybersecurity, real estate advisory, public relations, marketing and strategic consulting, were functionally dissimilar and that repeated post-search changes to the filters amounted to arbitrary cherry-picking. The Tribunal also accepted that, for a 100% export-oriented captive provider, export and turnover filters were relevant to comparability. On KPO characterisation, it held that recruitment, staffing, training and compliance support were routine operational services, and Rule 10TA could not override the factual analysis under Rule 10B.
Routine captive HR consultancy services of a low-risk service provider were benchmarked under TNMM on a cost-plus basis, and the Tribunal upheld the assessee's comparables on FAR analysis. It held that the TPO's substituted companies, engaged in IT consulting, software development, cybersecurity, real estate advisory, public relations, marketing and strategic consulting, were functionally dissimilar and that repeated post-search changes to the filters amounted to arbitrary cherry-picking. The Tribunal also accepted that, for a 100% export-oriented captive provider, export and turnover filters were relevant to comparability. On KPO characterisation, it held that recruitment, staffing, training and compliance support were routine operational services, and Rule 10TA could not override the factual analysis under Rule 10B.
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