Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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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