Preferential tariff claims under trade agreements require agreement-consistent origin checks, with safeguards against automatic denial for subsequent ...
Suppressed outward supplies require transaction-wise verification and reasoned findings before diary entries can support tax and penalty determination...
Transfer-pricing benchmarking of consultancy and civil-contracting services requires functional and financial comparability. Crux Consultants Pvt. Ltd. lacked publicly available audited financial statements and verifiable functional disclosures for the relevant year, preventing reliable analysis. Mahindra Consulting Engineers Ltd.'s multidisciplinary infrastructure and project-advisory operations, innovative project capabilities, and brand-related advantages materially differed from the assessee's profile. Kitco's substantial government and state-run project revenue and diversified activities, together with DRA Consultants Ltd.'s failure of the employee-cost filter, made all four unsuitable comparables. Their inclusion in the comparable set was set aside, while consequential matters remained open.
Transfer-pricing benchmarking of consultancy and civil-contracting services requires functional and financial comparability. Crux Consultants Pvt. Ltd. lacked publicly available audited financial statements and verifiable functional disclosures for the relevant year, preventing reliable analysis. Mahindra Consulting Engineers Ltd.'s multidisciplinary infrastructure and project-advisory operations, innovative project capabilities, and brand-related advantages materially differed from the assessee's profile. Kitco's substantial government and state-run project revenue and diversified activities, together with DRA Consultants Ltd.'s failure of the employee-cost filter, made all four unsuitable comparables. Their inclusion in the comparable set was set aside, while consequential matters remained open.
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