Handicraft job work receives concessional GST only for registered principals and predominantly handmade goods; commercial resin articles remain taxabl...
Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Functional comparability in transfer pricing turned on whether MPS Ltd. matched the assessee's ITES profile as a limited-risk content development and editing service provider. The Tribunal found MPS Ltd. materially different because it carried on broader content, publishing and accessibility solutions, operated multiple in-house platforms, undertook end-to-end and product development, conducted research and development, and expanded through acquisitions. As no segmental data isolated these activities, and coordinate bench rulings for the same year had also excluded it, MPS Ltd. was held not comparable and directed to be removed from the final set of comparables. Once excluded, the assessee's margin fell within the arm's length range and no transfer pricing adjustment survived.
Functional comparability in transfer pricing turned on whether MPS Ltd. matched the assessee's ITES profile as a limited-risk content development and editing service provider. The Tribunal found MPS Ltd. materially different because it carried on broader content, publishing and accessibility solutions, operated multiple in-house platforms, undertook end-to-end and product development, conducted research and development, and expanded through acquisitions. As no segmental data isolated these activities, and coordinate bench rulings for the same year had also excluded it, MPS Ltd. was held not comparable and directed to be removed from the final set of comparables. Once excluded, the assessee's margin fell within the arm's length range and no transfer pricing adjustment survived.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
