Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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...
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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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