Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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The Appellate Tribunal ruled on Transfer Pricing Adjustment, excluding companies with high turnover from comparables. Companies like Larsen & Toubro Infotech Ltd., Tata Elxsi Ltd., Persistent Systems Ltd., Aspire Systems Pvt. Ltd., and Infosys Ltd. were deemed incomparable due to substantial turnover difference. Infobeans Technologies Ltd. and Thirdware Solution Ltd. were considered comparable. Cigniti Technologies Ltd. was excluded for not meeting export revenue filter. Certain companies requested for inclusion were remanded for further assessment. Regarding interest on trade receivables, the Tribunal considered it an international transaction, benchmarking at 6% SBI rate due to lack of evidence on extended credit period. The appeal was partly allowed for statistical purposes.
The Appellate Tribunal ruled on Transfer Pricing Adjustment, excluding companies with high turnover from comparables. Companies like Larsen & Toubro Infotech Ltd., Tata Elxsi Ltd., Persistent Systems Ltd., Aspire Systems Pvt. Ltd., and Infosys Ltd. were deemed incomparable due to substantial turnover difference. Infobeans Technologies Ltd. and Thirdware Solution Ltd. were considered comparable. Cigniti Technologies Ltd. was excluded for not meeting export revenue filter. Certain companies requested for inclusion were remanded for further assessment. Regarding interest on trade receivables, the Tribunal considered it an international transaction, benchmarking at 6% SBI rate due to lack of evidence on extended credit period. The appeal was partly allowed for statistical purposes.
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