Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Captive IT/software development service providers may exclude giant comparables where the comparables' turnover is more than ten times the assessee's, so Infosys, Wipro, LTI Mindtree and Cybage were directed to be excluded. Where the remaining companies appeared to have diversified product, agency or consultancy functions, their FAR comparability could not be finally decided on the existing record, and the matter was remanded to the AO/TPO for fresh benchmarking. Delayed trade receivables from an associated enterprise were treated as a separate international transaction; interest was sustained in principle, but only after allowing a standard credit period before computing delay. The appeal was partly allowed for statistical purposes.
Captive IT/software development service providers may exclude giant comparables where the comparables' turnover is more than ten times the assessee's, so Infosys, Wipro, LTI Mindtree and Cybage were directed to be excluded. Where the remaining companies appeared to have diversified product, agency or consultancy functions, their FAR comparability could not be finally decided on the existing record, and the matter was remanded to the AO/TPO for fresh benchmarking. Delayed trade receivables from an associated enterprise were treated as a separate international transaction; interest was sustained in principle, but only after allowing a standard credit period before computing delay. The appeal was partly allowed for statistical purposes.
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