Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
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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