Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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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