Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Turnover is a relevant comparability factor in software development services under TNMM because scale affects profitability through economies of scale, bargaining strength and asset-risk profile; on that basis, the Tribunal excluded high-turnover companies from the final comparable set. It also accepted exclusion of three additional companies on the same reasoning. On delayed trade receivables, the Tribunal held that deferred receivables can constitute an international transaction, and that working capital adjustment does not automatically absorb invoice-wise delay beyond the agreed credit period. The interest adjustment was sustained in principle, but recomputation was directed after netting receivables and payables with the same associated enterprise and applying LIBOR plus 200 basis points for foreign-currency invoices.
Turnover is a relevant comparability factor in software development services under TNMM because scale affects profitability through economies of scale, bargaining strength and asset-risk profile; on that basis, the Tribunal excluded high-turnover companies from the final comparable set. It also accepted exclusion of three additional companies on the same reasoning. On delayed trade receivables, the Tribunal held that deferred receivables can constitute an international transaction, and that working capital adjustment does not automatically absorb invoice-wise delay beyond the agreed credit period. The interest adjustment was sustained in principle, but recomputation was directed after netting receivables and payables with the same associated enterprise and applying LIBOR plus 200 basis points for foreign-currency invoices.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
