Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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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