Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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.
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