Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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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