Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Transfer pricing comparables were tested on functional and...
Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocation.
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Transfer pricing comparables were tested on functional and factual suitability: India Tourism Development Corporation Limited was remanded for fresh examination because the loss-maker label was based on a misquoted record and profit had been shown in a relevant year; the healthcare segment of Inhouse Production Ltd. was directed to be included because segmental comparability was established; and Elbit Diagnostics Limited remained excluded because its operational circumstances made it an unsuitable comparable despite the persistent-loss reasoning failing. The Tribunal also directed working capital adjustment in line with the DRP's binding direction, accepted the assessee's no-risk status on a cost-plus, direction-driven model, and rejected objections to use of current-year data and the standard plus/minus 5 percent tolerance benefit.
Transfer pricing comparables were tested on functional and factual suitability: India Tourism Development Corporation Limited was remanded for fresh examination because the loss-maker label was based on a misquoted record and profit had been shown in a relevant year; the healthcare segment of Inhouse Production Ltd. was directed to be included because segmental comparability was established; and Elbit Diagnostics Limited remained excluded because its operational circumstances made it an unsuitable comparable despite the persistent-loss reasoning failing. The Tribunal also directed working capital adjustment in line with the DRP's binding direction, accepted the assessee's no-risk status on a cost-plus, direction-driven model, and rejected objections to use of current-year data and the standard plus/minus 5 percent tolerance benefit.
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