Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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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