Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
Page of 4786
Press 'Enter' after typing page number.
61 to 80 of 95714 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT upheld the exclusion of certain comparables previously deemed functionally dissimilar to the assessee, as established in the coordinate bench's earlier decision. It held that Sagarsoft India Ltd. is not functionally comparable and must be excluded, while other identified comparables are functionally similar and should be included for determining the arm's length price (ALP). The matter was remanded to the TPO to recompute the ALP incorporating the revised list of comparables. The TPO is directed to exclude and include comparables as specified and recalculate the ALP accordingly. If the resultant ALP falls within the prescribed tolerance range of +/-1%, no transfer pricing adjustment shall be made.
The ITAT upheld the exclusion of certain comparables previously deemed functionally dissimilar to the assessee, as established in the coordinate bench's earlier decision. It held that Sagarsoft India Ltd. is not functionally comparable and must be excluded, while other identified comparables are functionally similar and should be included for determining the arm's length price (ALP). The matter was remanded to the TPO to recompute the ALP incorporating the revised list of comparables. The TPO is directed to exclude and include comparables as specified and recalculate the ALP accordingly. If the resultant ALP falls within the prescribed tolerance range of +/-1%, no transfer pricing adjustment shall be made.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
