Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
The Appellate Tribunal held that negative working capital adjustment cannot be made for a captive service provider. L&T Infotech Ltd. and Infosys Ltd. were excluded from comparables as the assessee is a captive service provider compensated on a cost+mark-up basis. Persistent Systems Ltd. was excluded due to lack of segmental details. Infobeans Technologies Ltd. was found not functionally comparable. Tata Elxsi Ltd. was excluded as it generates revenue from product sales. Mindtree Ltd. & Nihilent Ltd. lacked segmental financials. Cygnet Infotech Pvt. Ltd. was excluded for not being a captive service provider. Cybage Software Pvt. Ltd. was excluded due to diversified activities. Batchmaster Software Pvt. Ltd. was remanded for further verification. The issue of deduction u/s. 10AA and interest levy u/s. 234A, 234B, 234C requires verification by the assessing officer based on evidence provided by the assessee.
The Appellate Tribunal held that negative working capital adjustment cannot be made for a captive service provider. L&T Infotech Ltd. and Infosys Ltd. were excluded from comparables as the assessee is a captive service provider compensated on a cost+mark-up basis. Persistent Systems Ltd. was excluded due to lack of segmental details. Infobeans Technologies Ltd. was found not functionally comparable. Tata Elxsi Ltd. was excluded as it generates revenue from product sales. Mindtree Ltd. & Nihilent Ltd. lacked segmental financials. Cygnet Infotech Pvt. Ltd. was excluded for not being a captive service provider. Cybage Software Pvt. Ltd. was excluded due to diversified activities. Batchmaster Software Pvt. Ltd. was remanded for further verification. The issue of deduction u/s. 10AA and interest levy u/s. 234A, 234B, 234C requires verification by the assessing officer based on evidence provided by the assessee.
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