Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Transfer pricing comparables for IT support services were adjusted by including Rheal Software Pvt. Ltd. and Toxsl Technologies Private Ltd., as the first was not a persistent loss maker and the second was functionally similar and could be raised before the appellate authority. Unearned revenue shown as customer advances was held not to be unexplained cash credit because the assessee had produced supporting records and the amounts were accepted in later years without adverse material, so the addition was deleted. Foreign exchange fluctuation loss was also deleted since the net exchange difference had already been reflected in the audited accounts and taxable income. Interest and fee were remanded for fresh recomputation after opportunity to the assessee.
Transfer pricing comparables for IT support services were adjusted by including Rheal Software Pvt. Ltd. and Toxsl Technologies Private Ltd., as the first was not a persistent loss maker and the second was functionally similar and could be raised before the appellate authority. Unearned revenue shown as customer advances was held not to be unexplained cash credit because the assessee had produced supporting records and the amounts were accepted in later years without adverse material, so the addition was deleted. Foreign exchange fluctuation loss was also deleted since the net exchange difference had already been reflected in the audited accounts and taxable income. Interest and fee were remanded for fresh recomputation after opportunity to the assessee.
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