Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
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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