Compromise-and-arrangement extensions may accommodate debt assignment where creditor commercial judgment supports value maximisation and avoids proced...
Delayed-payment surcharge is not taxable tolerance consideration where it penalises default, while meter testing follows electricity distribution trea...
Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appea...
Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Retrospective insertion of section 144C(13A) places the final...
Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjustment.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Retrospective insertion of section 144C(13A) places the final assessment order within the prescribed limitation period, rejecting the time-bar challenge. Cost-to-cost recovery of withholding tax paid for associated enterprises' restricted stock units is non-operating because it is unrelated to the assessee's ITeS services, and must be excluded from its operating margin. Voice-based call-centre, general IT/BPO, technical-helpdesk and intellectual-property consultancy providers are functionally incomparable with diversified technical ITeS services, while knowledge-processing services may remain comparable. Delayed associated-enterprise receivables, though international transactions, require combined benchmarking with the underlying ITeS transaction; once a working-capital adjustment is granted under TNMM, separate notional interest is unwarranted.
Retrospective insertion of section 144C(13A) places the final assessment order within the prescribed limitation period, rejecting the time-bar challenge. Cost-to-cost recovery of withholding tax paid for associated enterprises' restricted stock units is non-operating because it is unrelated to the assessee's ITeS services, and must be excluded from its operating margin. Voice-based call-centre, general IT/BPO, technical-helpdesk and intellectual-property consultancy providers are functionally incomparable with diversified technical ITeS services, while knowledge-processing services may remain comparable. Delayed associated-enterprise receivables, though international transactions, require combined benchmarking with the underlying ITeS transaction; once a working-capital adjustment is granted under TNMM, separate notional interest is unwarranted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
