Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
In transfer pricing benchmarking for SWD and captive ITeS services, comparables were excluded where functional dissimilarity, significant intangibles and brand value, unreliable segmental data, RPT failures, extraordinary events, abnormal margins and high turnover undermined comparability; high receivables alone was not treated as enough to reject an otherwise functionally similar company. Akshay Software Technologies was remanded for fresh FAR verification because service descriptions alone cannot justify exclusion, while negative working capital adjustment was held impermissible for a captive cost-plus service provider not bearing such risk. The specific claims for Sasken Communication Technologies and Informed Technologies India were also restored for fresh examination, and the Revenue's appeal was dismissed.
In transfer pricing benchmarking for SWD and captive ITeS services, comparables were excluded where functional dissimilarity, significant intangibles and brand value, unreliable segmental data, RPT failures, extraordinary events, abnormal margins and high turnover undermined comparability; high receivables alone was not treated as enough to reject an otherwise functionally similar company. Akshay Software Technologies was remanded for fresh FAR verification because service descriptions alone cannot justify exclusion, while negative working capital adjustment was held impermissible for a captive cost-plus service provider not bearing such risk. The specific claims for Sasken Communication Technologies and Informed Technologies India were also restored for fresh examination, and the Revenue's appeal was dismissed.
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