Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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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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