AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
