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...
In transfer pricing benchmarking for captive software support and ITES services, companies with significant intangibles, brand value, patents, R&D functions, product-based operations, diversified activities or extraordinary events were found functionally dissimilar and excluded as comparables. Infosys Technologies Ltd., Wipro Ltd., Kals Information Systems Ltd., Celestial Labs Ltd., Avani Cimcon Technologies Ltd., E-Zest Solutions Ltd., Mold-Tek Technologies Ltd., Accentia Technologies Ltd., Eclerx Services Ltd., Infosys BPO Ltd., HCL Comnet System & Services Ltd., Acropetal Technologies Ltd., Genesys International Corporation Ltd. and Datamatics Financial Services Ltd. were excluded. Tata Elxsi Ltd. and Persistent Systems Private Ltd. were remitted for fresh consideration because no specific examination had been made. Coral Hub Ltd. remained included as the objection was not pressed.
In transfer pricing benchmarking for captive software support and ITES services, companies with significant intangibles, brand value, patents, R&D functions, product-based operations, diversified activities or extraordinary events were found functionally dissimilar and excluded as comparables. Infosys Technologies Ltd., Wipro Ltd., Kals Information Systems Ltd., Celestial Labs Ltd., Avani Cimcon Technologies Ltd., E-Zest Solutions Ltd., Mold-Tek Technologies Ltd., Accentia Technologies Ltd., Eclerx Services Ltd., Infosys BPO Ltd., HCL Comnet System & Services Ltd., Acropetal Technologies Ltd., Genesys International Corporation Ltd. and Datamatics Financial Services Ltd. were excluded. Tata Elxsi Ltd. and Persistent Systems Private Ltd. were remitted for fresh consideration because no specific examination had been made. Coral Hub Ltd. remained included as the objection was not pressed.
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