Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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ITAT ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee's ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.
ITAT ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee's ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.
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