Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
