International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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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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