Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
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...
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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