Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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In a transfer pricing dispute, the Tribunal held that Onward Technologies Ltd. remained a valid comparable for benchmarking the engineering, technical and inspection services segment because the TPO/AO had accepted its segmental results and the CIT(A) had also upheld that position. The Revenue's attempt to seek exclusion of the company as functionally not comparable was rejected as misconceived, since the objection was raised for the first time before the Tribunal after acceptance at the earlier stages. The additional grounds were therefore dismissed, and the Revenue's appeal failed.
In a transfer pricing dispute, the Tribunal held that Onward Technologies Ltd. remained a valid comparable for benchmarking the engineering, technical and inspection services segment because the TPO/AO had accepted its segmental results and the CIT(A) had also upheld that position. The Revenue's attempt to seek exclusion of the company as functionally not comparable was rejected as misconceived, since the objection was raised for the first time before the Tribunal after acceptance at the earlier stages. The additional grounds were therefore dismissed, and the Revenue's appeal failed.
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