Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
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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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