Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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.
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