Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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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