COVID-19 limitation exclusion and destination-specific e-way bills govern revisional timelines and penalties for undocumented third-party plywood deli...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
