Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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Turnover was held to be a relevant comparability factor in ITES benchmarking: where the assessee maintained separate segmental results and the dispute concerned a small ITES segment, comparables with vastly higher turnover were excluded because their scale and capabilities were not comparable. The Tribunal also held that transfer pricing adjustment can be made only in respect of international transactions and must be confined to revenue from associated enterprise dealings, not the entire business turnover. On the section 40(a)(i) issue relating to testing charges, the matter was restored to the Assessing Officer for fresh consideration in line with the assessee's earlier year.
Turnover was held to be a relevant comparability factor in ITES benchmarking: where the assessee maintained separate segmental results and the dispute concerned a small ITES segment, comparables with vastly higher turnover were excluded because their scale and capabilities were not comparable. The Tribunal also held that transfer pricing adjustment can be made only in respect of international transactions and must be confined to revenue from associated enterprise dealings, not the entire business turnover. On the section 40(a)(i) issue relating to testing charges, the matter was restored to the Assessing Officer for fresh consideration in line with the assessee's earlier year.
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