Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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