Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after completion of the search process with the object of excluding comparables which was otherwise found to be functionally comparables after the Functions Assets Risks (FAR) Analysis. - The application of the second lower turnover filter by the TPO without rejecting the first turnover filter adopted by the Appellant resulted exclusion of two companies which were otherwise functionally comparable and thus, resulted in cherry picking. - TPO directed to recompute the arm's length price (ALP) accordingly.
TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after completion of the search process with the object of excluding comparables which was otherwise found to be functionally comparables after the Functions Assets Risks (FAR) Analysis. - The application of the second lower turnover filter by the TPO without rejecting the first turnover filter adopted by the Appellant resulted exclusion of two companies which were otherwise functionally comparable and thus, resulted in cherry picking. - TPO directed to recompute the arm's length price (ALP) accordingly.
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