Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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...
ITAT directs selective inclusion and exclusion of comparables across multiple service segments. Key determinations include excluding Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd due to limited risk profile, remanding certain comparables for detailed verification, and accepting specific companies like Sonata Information Technology Ltd and Akshay Software Technologies Ltd. The tribunal mandated working capital adjustments and proportionate margin computations, emphasizing functional similarity and segmental compatibility as primary criteria for comparable selection. The ruling instructs the Assessing Officer to comprehensively re-evaluate comparable companies using precise filtering parameters across software development, IT-enabled services, and training segments.
ITAT directs selective inclusion and exclusion of comparables across multiple service segments. Key determinations include excluding Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd due to limited risk profile, remanding certain comparables for detailed verification, and accepting specific companies like Sonata Information Technology Ltd and Akshay Software Technologies Ltd. The tribunal mandated working capital adjustments and proportionate margin computations, emphasizing functional similarity and segmental compatibility as primary criteria for comparable selection. The ruling instructs the Assessing Officer to comprehensively re-evaluate comparable companies using precise filtering parameters across software development, IT-enabled services, and training segments.
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