Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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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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