Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Transfer pricing comparables had to be tested against functional similarity, related party transaction limits, segmental data and trading sales filters, and the Assessing Officer was required to follow DRP directions. Peoplelink Unified Communications Pvt. Ltd. was to be excluded because it had already been found functionally different. Zoho Corporation Pvt. Ltd., Quick Heal Technologies Ltd. and RAH Infotech Pvt. Ltd., MSR IT Solution Pvt Ltd. and ESDS Corporation Pvt. Ltd. were sent back for re-examination on the stated filters and annual report data. The operating margin of Compass IT Solutions and Services Pvt Ltd. was also to be verified and corrected if the wrong margin had been applied. Working capital adjustment had to be granted as directed, while consequential interest did not survive on merits.
Transfer pricing comparables had to be tested against functional similarity, related party transaction limits, segmental data and trading sales filters, and the Assessing Officer was required to follow DRP directions. Peoplelink Unified Communications Pvt. Ltd. was to be excluded because it had already been found functionally different. Zoho Corporation Pvt. Ltd., Quick Heal Technologies Ltd. and RAH Infotech Pvt. Ltd., MSR IT Solution Pvt Ltd. and ESDS Corporation Pvt. Ltd. were sent back for re-examination on the stated filters and annual report data. The operating margin of Compass IT Solutions and Services Pvt Ltd. was also to be verified and corrected if the wrong margin had been applied. Working capital adjustment had to be granted as directed, while consequential interest did not survive on merits.
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