Foreign portfolio investment liberalisation extends listed equity access to all individual persons resident outside India, subject to limit monitoring...
Unsubstantiated exempt agricultural income claim sustains concealment penalty after disclosure only on departmental detection and no bona fide evidenc...
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In transfer pricing for captive software development services, high turnover comparables were excluded because a wide turnover gap distorts economies of scale, brand value, market positioning and risk profile; entities with turnover above 200 crore were therefore removed and the arm's length price recomputed. Companies with diversified or specialised functions outside captive software development were also excluded as functionally dissimilar, leading to fresh computation of the profit level indicator and ALP. For delayed foreign currency trade receivables, SBI PLR was rejected as an inappropriate domestic benchmark, and LIBOR plus 200 basis points was applied after allowing the agreed or standard credit period for recomputation of the adjustment.
In transfer pricing for captive software development services, high turnover comparables were excluded because a wide turnover gap distorts economies of scale, brand value, market positioning and risk profile; entities with turnover above 200 crore were therefore removed and the arm's length price recomputed. Companies with diversified or specialised functions outside captive software development were also excluded as functionally dissimilar, leading to fresh computation of the profit level indicator and ALP. For delayed foreign currency trade receivables, SBI PLR was rejected as an inappropriate domestic benchmark, and LIBOR plus 200 basis points was applied after allowing the agreed or standard credit period for recomputation of the adjustment.
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