Equivalent-value attachment can reach pre-existing assets, but jointly owned property remains protected beyond the accused's attributable proceeds of ...
Pre-registration physical verification becomes mandatory to prevent non-existent business registrations and support timely GST registration processing...
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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TaxTMI 
TaxTMI 
of 4884 
