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...
ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin.
ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
