Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
Export turnover and total turnover must be computed on a parity basis for Section 10A deduction, so foreign-exchange expenditure excluded from export turnover must also be excluded from total turnover; the issue was decided for the assessee. Depreciation claims relating to goodwill and non-compete rights were not finally determined, as the matter was remitted for reconsideration in light of the Supreme Court's guidance on acquisition parameters. Apportionment of common disallowance between STP and non-STP units was treated as a factual question, and the concurrent view that a lump-sum disallowance was improper was upheld for the assessee. Interest disallowance on advances to subsidiaries was remitted for fresh examination on whether the investment had a business nexus.
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