Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
TP adjustment - ALP of Contract Software Development (CSD Segment) - Comparable selection - The Tribunal upheld the exclusion of certain comparables based on functional dissimilarity with the assessee. However, it directed the Assessing Officer to re-examine the inclusion/exclusion criteria and the impact of amalgamation on profitability for certain comparables. - Regarding the issue of Adjustment of notional interest on overdue receivables from AEs: The Tribunal observed a pattern of intentional delays in payments to AEs, potentially benefiting them. However, it noted that the issue required further examination concerning the impact on working capital adjustment and the application of principles laid down by the jurisdictional High Court.
TP adjustment - ALP of Contract Software Development (CSD Segment) - Comparable selection - The Tribunal upheld the exclusion of certain comparables based on functional dissimilarity with the assessee. However, it directed the Assessing Officer to re-examine the inclusion/exclusion criteria and the impact of amalgamation on profitability for certain comparables. - Regarding the issue of Adjustment of notional interest on overdue receivables from AEs: The Tribunal observed a pattern of intentional delays in payments to AEs, potentially benefiting them. However, it noted that the issue required further examination concerning the impact on working capital adjustment and the application of principles laid down by the jurisdictional High Court.
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