Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
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Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
Intra-group software licence costs are examined through inter-company invoices, third-party licensing agreements, allocation workings and supporting invoices to establish actual availing and the allocation basis for arm's length pricing. The notes state that a nil arm's length price was not justified where this evidence was furnished. For low-end IS&T services, Dispute Resolution Panel directions require verification of segmental audited revenue and recomputation of operating margins; cost-to-cost IT reimbursements must be treated consistently with those directions. Eclerx Services Ltd. is identified as functionally and operationally incomparable. Reversal of a previously disallowed bonus provision requires verification before deduction, and a pending rectification application must be decided before a fresh order.
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