Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
Turnover is a relevant comparability criterion in transfer pricing because scale affects profitability, risk profile, asset base, bargaining power and economies of scale; the Tribunal therefore upheld use of an upper turnover filter and rejected the Revenue's challenge to exclusion of high-turnover comparables. For inclusion of I2T2 India Limited and Cigniti Technologies Limited, the Tribunal held that a comparable cannot be adopted merely by relying on an earlier order without verifying contemporaneous financials, functional profile, applicable filters and segmental data for the year in question; that issue was remanded to the Assessing Officer/TPO for fresh examination after hearing the assessee.
Turnover is a relevant comparability criterion in transfer pricing because scale affects profitability, risk profile, asset base, bargaining power and economies of scale; the Tribunal therefore upheld use of an upper turnover filter and rejected the Revenue's challenge to exclusion of high-turnover comparables. For inclusion of I2T2 India Limited and Cigniti Technologies Limited, the Tribunal held that a comparable cannot be adopted merely by relying on an earlier order without verifying contemporaneous financials, functional profile, applicable filters and segmental data for the year in question; that issue was remanded to the Assessing Officer/TPO for fresh examination after hearing the assessee.
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