Unlawful outward remittances via Hawala using proforma invoices and electronic records proved; documents admitted, directors penalised, penalties redu...
Attachment of equivalent-value properties as proceeds of crime upheld; preventive attachment order and confirmation sustained; no independent ED reinv...
Broker trading-system "technical glitch" redefinition and narrowed incident-reporting regime for large IBT/STWT brokers requiring 2-hr notice and 14-w...
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 4819 
Join Channel 
