Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
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In transfer pricing comparability analysis for a manufacturing segment, the ITAT treated the Safe Harbour definitions of core and non-core auto components as a guiding aid for FAR analysis even though the assessee had not opted for Safe Harbour Rules. Because the assessee manufactured shock absorbers in the core auto component segment, only functionally similar comparables were acceptable. Helmet and accessory manufacturers, Eicher Motors, and Special Engineering Services were excluded for functional dissimilarity; Nifco was also excluded because its related party transactions exceeded 25%, despite otherwise being in the automotive component space.
In transfer pricing comparability analysis for a manufacturing segment, the ITAT treated the Safe Harbour definitions of core and non-core auto components as a guiding aid for FAR analysis even though the assessee had not opted for Safe Harbour Rules. Because the assessee manufactured shock absorbers in the core auto component segment, only functionally similar comparables were acceptable. Helmet and accessory manufacturers, Eicher Motors, and Special Engineering Services were excluded for functional dissimilarity; Nifco was also excluded because its related party transactions exceeded 25%, despite otherwise being in the automotive component space.
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