Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Personal guarantor insolvency jurisdiction follows the corporate debtor's CIRP Bench, enabling inter-territorial transfer and preventing parallel proc...
Section 47-A undervaluation threshold: fraudulent intent requirement faces reconsideration after referral to a larger Bench for authoritative resoluti...
RBI supersession powers over multi-State co-operative banks operate independently of the constitutional six-month ceiling and permit statutory extensi...
Captive contract software-development services are benchmarked against companies performing comparable software-development functions, assets and risks; product-development businesses, complex digital-product providers and companies lacking relevant segmental information are unsuitable. Companies earning software-development service revenue may remain comparable where no material functional difference is established, while entities exceeding the applicable related-party transaction filter must be excluded. Where delayed trade receivables arise solely from the service transaction benchmarked under TNMM, they require combined benchmarking. Working-capital adjustment for material differences subsumes the receivables effect, so separate notional interest is unwarranted. Financials of an unverified proposed comparable require verification against applicable filters, and assessed income should be rectified using correct figures.
Captive contract software-development services are benchmarked against companies performing comparable software-development functions, assets and risks; product-development businesses, complex digital-product providers and companies lacking relevant segmental information are unsuitable. Companies earning software-development service revenue may remain comparable where no material functional difference is established, while entities exceeding the applicable related-party transaction filter must be excluded. Where delayed trade receivables arise solely from the service transaction benchmarked under TNMM, they require combined benchmarking. Working-capital adjustment for material differences subsumes the receivables effect, so separate notional interest is unwarranted. Financials of an unverified proposed comparable require verification against applicable filters, and assessed income should be rectified using correct figures.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
