Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
In transfer pricing for export of data processing and office support services, comparability must be tested on both export turnover and functional similarity. Cepha Imaging Pvt. Ltd. could not be accepted or rejected merely by verifying export turnover; the Tribunal was required to examine whether its e-publishing activity was functionally comparable to IT-enabled services, especially in light of the CBDT notification excluding e-publishing. CG Vak Software & Exports Ltd. was also held to be an unsuitable comparable because the extreme disparity in turnover and scale of operations materially affected comparability. The TPO was therefore directed to reassess Cepha Imaging on functional similarity and CG Vak was excluded as a comparable.
In transfer pricing for export of data processing and office support services, comparability must be tested on both export turnover and functional similarity. Cepha Imaging Pvt. Ltd. could not be accepted or rejected merely by verifying export turnover; the Tribunal was required to examine whether its e-publishing activity was functionally comparable to IT-enabled services, especially in light of the CBDT notification excluding e-publishing. CG Vak Software & Exports Ltd. was also held to be an unsuitable comparable because the extreme disparity in turnover and scale of operations materially affected comparability. The TPO was therefore directed to reassess Cepha Imaging on functional similarity and CG Vak was excluded as a comparable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
