Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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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