Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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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