Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
