Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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The High Court upheld the decision of the ITAT regarding the selection of comparables for benchmarking analysis under the Transactional Net Margin Method (TNMM). The court concurred that companies like Kitco Ltd., TCE Consulting Engineers Ltd., Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. were not appropriate comparables for the assessee, who was engaged in engineering and design services. Despite the TNMM's tolerance for functional dissimilarities, the comparables' broad functional profiles must be similar. Comparing entities with different functionalities solely based on the TNMM's tolerance would be erroneous. The ITAT's findings aligned with the arm's length principle provisions u/s 92C of the Income Tax Act.
The High Court upheld the decision of the ITAT regarding the selection of comparables for benchmarking analysis under the Transactional Net Margin Method (TNMM). The court concurred that companies like Kitco Ltd., TCE Consulting Engineers Ltd., Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. were not appropriate comparables for the assessee, who was engaged in engineering and design services. Despite the TNMM's tolerance for functional dissimilarities, the comparables' broad functional profiles must be similar. Comparing entities with different functionalities solely based on the TNMM's tolerance would be erroneous. The ITAT's findings aligned with the arm's length principle provisions u/s 92C of the Income Tax Act.
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