Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
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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