Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
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