Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
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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