Approved gratuity fund provisions remain deductible despite general actual-payment requirements, preventing revision of the allowed gratuity deduction...
Verification of intangible software expenditure and duplicated disallowances requires record-based reassessment before depreciation and income computa...
Cash receipt aggregation requires a single transaction, event or occasion; separate partner capital contributions cannot attract cash-receipt penaltie...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4925 
