Faceless assessment and registration procedures are updated through electronic communication, revised recovery rules, extended deadlines, and replacem...
Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
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 4879 
