Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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.
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