Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
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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