NPCI-based bank account validation for IEC applications and modifications enables real-time validation; incorrect details block submission or trigger ...
Creation/Invocation of pledge of securities through depository system: standardized pledge forms, notice requirement and invocation notifications to p...
Calendar Spread margin benefit for Single Stock Derivatives suspended on expiry day for expiring contracts; exchanges must implement systems and rule ...
Proportionate interest, unexplained credits and partner remuneration disputed; proofs of fund nexus and lender identity were decisive and disallowance...
Capital gains valuation from stamp assessment versus net consideration for residential reinvestment: deemed stamp value replaced for gains but not for...
Persistent Systems Ltd. was rejected as a comparable under TNMM because the assessee was a captive software development service provider, while Persistent operated an IP-led product development model with product, licensing and other mixed revenues, different risk profile, and no segmental break-up. Akshay Software Technologies Ltd., Cigniti Technologies Ltd. and Evoke Technologies Pvt. Ltd. were accepted as comparables because their software-related activities, quantitative filters and reliable financial data supported inclusion. Foreign tax credit was restored for verification of supporting documents, including Form 67, withholding proof and Indian taxability of the corresponding income, and working capital adjustment was directed after verification in accordance with law. Both appeals were partly allowed.
Persistent Systems Ltd. was rejected as a comparable under TNMM because the assessee was a captive software development service provider, while Persistent operated an IP-led product development model with product, licensing and other mixed revenues, different risk profile, and no segmental break-up. Akshay Software Technologies Ltd., Cigniti Technologies Ltd. and Evoke Technologies Pvt. Ltd. were accepted as comparables because their software-related activities, quantitative filters and reliable financial data supported inclusion. Foreign tax credit was restored for verification of supporting documents, including Form 67, withholding proof and Indian taxability of the corresponding income, and working capital adjustment was directed after verification in accordance with law. Both appeals were partly allowed.
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