Input tax credit conditions remain constitutionally valid, with eligible recipient claims considered under GST circulars and retrospective filing dead...
Bogus donation receipts justified commission income assessment and defeated political-party tax exemption for inaccurate accounts and reporting failur...
Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
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 4823 
Join Channel 
