Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Functional comparability of IT-enabled BPO service providers requires exclusion of entities with materially different business models, including providers that outsource most services, operate at a substantially larger branded scale, perform high-end KPO or engineering-design functions, or lack relevant segmental information. A consistently accepted comparable may remain included where no material distinction exists. These principles supported deletion of the transfer-pricing adjustment. IT-enabled back-office and data-processing services covered by notified activities qualify as export of computer software for the claimed deduction. Where identical deductions were allowed in earlier years and circumstances remain unchanged, the consistency principle supports allowance. The Revenue's appeal was dismissed.
Functional comparability of IT-enabled BPO service providers requires exclusion of entities with materially different business models, including providers that outsource most services, operate at a substantially larger branded scale, perform high-end KPO or engineering-design functions, or lack relevant segmental information. A consistently accepted comparable may remain included where no material distinction exists. These principles supported deletion of the transfer-pricing adjustment. IT-enabled back-office and data-processing services covered by notified activities qualify as export of computer software for the claimed deduction. Where identical deductions were allowed in earlier years and circumstances remain unchanged, the consistency principle supports allowance. The Revenue's appeal was dismissed.
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