Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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