Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
In transfer pricing benchmarking for contract R&D support services, the Tribunal held that the expression "persistent loss-making" could not exclude comparables that had losses only in earlier years but profits in the year under review; Micro Therapeutic Research Labs Ltd. and Choksi Laboratories Ltd. were therefore to be retained as comparables. It also held that quantitative turnover filters may be relaxed pragmatically where deviation is marginal and functional comparability is otherwise undisputed; Micro Therapeutic Research Labs Ltd. was included despite exceeding the upper threshold only slightly. On inclusion of these comparables, the assessee's margin was found to be within the arm's length range, so the transfer pricing adjustment was deleted. Interest was consequential and initiation of penalty was premature.
In transfer pricing benchmarking for contract R&D support services, the Tribunal held that the expression "persistent loss-making" could not exclude comparables that had losses only in earlier years but profits in the year under review; Micro Therapeutic Research Labs Ltd. and Choksi Laboratories Ltd. were therefore to be retained as comparables. It also held that quantitative turnover filters may be relaxed pragmatically where deviation is marginal and functional comparability is otherwise undisputed; Micro Therapeutic Research Labs Ltd. was included despite exceeding the upper threshold only slightly. On inclusion of these comparables, the assessee's margin was found to be within the arm's length range, so the transfer pricing adjustment was deleted. Interest was consequential and initiation of penalty was premature.
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