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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Comparable selection for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.
Comparable selection for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.
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