Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
In transfer pricing under TNMM, functionally dissimilar companies and those failing accepted filters cannot be retained as comparables merely because they were initially selected by the assessee. Larsen & Toubro Infotech Ltd., Manipal Digital Systems Pvt. Ltd., E-Care India Pvt. Ltd. and Ultramarine & Pigments Ltd. were directed to be excluded from the final comparable set for the back-office support services segment. The Tribunal also construed section 144C(13) as requiring the final assessment to be completed within one month from the end of the month in which DRP directions are received; because the order was passed after that period, it treated the assessment as time-barred, invalid and quashed it.
In transfer pricing under TNMM, functionally dissimilar companies and those failing accepted filters cannot be retained as comparables merely because they were initially selected by the assessee. Larsen & Toubro Infotech Ltd., Manipal Digital Systems Pvt. Ltd., E-Care India Pvt. Ltd. and Ultramarine & Pigments Ltd. were directed to be excluded from the final comparable set for the back-office support services segment. The Tribunal also construed section 144C(13) as requiring the final assessment to be completed within one month from the end of the month in which DRP directions are received; because the order was passed after that period, it treated the assessment as time-barred, invalid and quashed it.
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