Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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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