Penalty for estimation of income and disallowances for tax non-deduction clarified: estimation-based penalties not sustainable; additions without conc...
Managerial remuneration disallowance under s.40A(2)(b) challenged over alleged tax-avoidance; appellate decision restored deletion of addition for dir...
Classification of imported goods as electronic cigarette versus tobacco product reversed for lack of proof; order set aside for jurisdictional overrea...
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.
Note: It is a system-generated summary and is for quick reference only.