Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
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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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