Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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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