Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
The ITAT held that the comparable company selected by the TPO for transfer pricing adjustment did not match the functional profile of the assessee and thus must be excluded from the comparable set. Regarding other comparables, the tribunal directed the AO/TPO to reconsider their inclusion afresh, applying appropriate filters and providing the assessee a reasonable opportunity to be heard and submit supporting documents. The appeal was partly allowed for statistical purposes, remanding the matter for further examination consistent with the directions.
The ITAT held that the comparable company selected by the TPO for transfer pricing adjustment did not match the functional profile of the assessee and thus must be excluded from the comparable set. Regarding other comparables, the tribunal directed the AO/TPO to reconsider their inclusion afresh, applying appropriate filters and providing the assessee a reasonable opportunity to be heard and submit supporting documents. The appeal was partly allowed for statistical purposes, remanding the matter for further examination consistent with the directions.
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