Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Transfer pricing analysis turned on comparability and receivables benchmarking. EClerx Services Limited was excluded as a KPO, and Infosys BPO Limited was excluded because of its large turnover and intangibles; the Tribunal accepted the consistent approach taken in the assessee's own earlier years and declined remand for fresh benchmarking. Interest on outstanding receivables was upheld at LIBOR plus 200 basis points, following the assessee's prior year treatment and rejecting the SBI term deposit rate. The 120-day credit period was set aside as case-specific and was to follow the period adopted in the assessee's own case for AY 2013-14; section 92CE and Rule 10CB were held inapplicable by analogy.
Transfer pricing analysis turned on comparability and receivables benchmarking. EClerx Services Limited was excluded as a KPO, and Infosys BPO Limited was excluded because of its large turnover and intangibles; the Tribunal accepted the consistent approach taken in the assessee's own earlier years and declined remand for fresh benchmarking. Interest on outstanding receivables was upheld at LIBOR plus 200 basis points, following the assessee's prior year treatment and rejecting the SBI term deposit rate. The 120-day credit period was set aside as case-specific and was to follow the period adopted in the assessee's own case for AY 2013-14; section 92CE and Rule 10CB were held inapplicable by analogy.
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