Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
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