Maintainability of a Section 7 insolvency petition against a financial service provider denied; appeal dismissed for non maintainability and complex d...
Provisional attachment under Prevention of Money Laundering Act requires exhaustion of statutory remedies; impugned order set aside, appeal to tribuna...
Restoration of property under Prevention of Money Laundering Act after attachment dispute rendered academic; possession directed to successful resolut...
Transfer pricing adjustment based on selection of comparables was challenged on the ground that the excluded companies should have been retained. The court upheld exclusion because the fact-finding authority had concluded that the proposed comparables failed the functional similarity test, being engaged in activities other than the tested export service activity, and also failed the 75% export turnover filter since their export income was materially below the threshold while the tested party's revenue was entirely export-derived. As these determinations were pure findings of fact accepted by the appellate tribunal, no substantial question of law arose, and the appeal was dismissed. - HC
Transfer pricing adjustment based on selection of comparables was challenged on the ground that the excluded companies should have been retained. The court upheld exclusion because the fact-finding authority had concluded that the proposed comparables failed the functional similarity test, being engaged in activities other than the tested export service activity, and also failed the 75% export turnover filter since their export income was materially below the threshold while the tested party's revenue was entirely export-derived. As these determinations were pure findings of fact accepted by the appellate tribunal, no substantial question of law arose, and the appeal was dismissed. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
