Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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