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...
Applying a 25% related-party transaction filter, the Tribunal excluded Liquidhub Analytics Private Limited because its RPT level exceeded the prescribed threshold and it could not be treated as an uncontrolled comparable. It held that the search matrix is only a tool for identifying comparables, so rejection of the assessee's proposed comparables merely for absence from that matrix was unsustainable; the matter was remitted for fresh FAR analysis and filter-based examination. The Tribunal also required parity between cost and revenue in ESOP reimbursement under a cost-plus model, directed fresh working capital adjustment analysis, and upheld receivables adjustment in principle while requiring recomputation at LIBOR plus 200 basis points for delay beyond the agreed credit period.
Applying a 25% related-party transaction filter, the Tribunal excluded Liquidhub Analytics Private Limited because its RPT level exceeded the prescribed threshold and it could not be treated as an uncontrolled comparable. It held that the search matrix is only a tool for identifying comparables, so rejection of the assessee's proposed comparables merely for absence from that matrix was unsustainable; the matter was remitted for fresh FAR analysis and filter-based examination. The Tribunal also required parity between cost and revenue in ESOP reimbursement under a cost-plus model, directed fresh working capital adjustment analysis, and upheld receivables adjustment in principle while requiring recomputation at LIBOR plus 200 basis points for delay beyond the agreed credit period.
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