Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
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