Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
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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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