Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Transfer pricing comparables for basic market research and testing services turned on functional comparability and related party screening. India Tourism Development Corporation Ltd. was retained as a comparable, while Unimed Diagnostics Private Limited, Medall Healthcare Private Limited, IGT Solutions Private Limited and Fuzen Software Private Limited were treated as functionally dissimilar because their business models differed from information-gathering and data-compilation services. The note also records that depreciation on computer software and disallowance of international travel expenses were sent back for fresh verification because the DRP directions had not been properly implemented.
Transfer pricing comparables for basic market research and testing services turned on functional comparability and related party screening. India Tourism Development Corporation Ltd. was retained as a comparable, while Unimed Diagnostics Private Limited, Medall Healthcare Private Limited, IGT Solutions Private Limited and Fuzen Software Private Limited were treated as functionally dissimilar because their business models differed from information-gathering and data-compilation services. The note also records that depreciation on computer software and disallowance of international travel expenses were sent back for fresh verification because the DRP directions had not been properly implemented.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
