Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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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