Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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 4813 
Join Channel 
