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Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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.
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