Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing comparability was applied on functional profile and reliable data: Datamatics Business Solutions was excluded because it performed high-end KPO functions unlike a routine captive BPO, while R Systems International could be included if quarterly public results enable a reliable margin computation. Micro Land was included on consistency grounds despite not appearing in the search matrix. Working capital differences under TNMM required fresh verification, and interest on delayed foreign-currency receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The section 43B disallowance was restored for factual verification, and interest under sections 234A and 234C was held unsustainable or required recomputation in the assessee's favour.
Transfer pricing comparability was applied on functional profile and reliable data: Datamatics Business Solutions was excluded because it performed high-end KPO functions unlike a routine captive BPO, while R Systems International could be included if quarterly public results enable a reliable margin computation. Micro Land was included on consistency grounds despite not appearing in the search matrix. Working capital differences under TNMM required fresh verification, and interest on delayed foreign-currency receivables was to be recomputed using LIBOR plus 200 basis points for the actual delay period. The section 43B disallowance was restored for factual verification, and interest under sections 234A and 234C was held unsustainable or required recomputation in the assessee's favour.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
