Call-recording requirements for institutional-investor client communications become non-mandatory, while institutional-investor status adopts the exis...
Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Rule 10B does not prescribe a lower or upper turnover limit for transfer-pricing comparables in the software development services segment. Market conditions, assets employed and risks assumed remain material to comparability analysis. An upper turnover filter may therefore be applied where it rationally distinguishes companies with materially different scale and economic profiles. Its application is a factual determination and is not open to interference unless perversity is pleaded and demonstrated. The Tribunal's use of the filter consequently raised no substantial question of law, and the Revenue's appeal was dismissed.
Rule 10B does not prescribe a lower or upper turnover limit for transfer-pricing comparables in the software development services segment. Market conditions, assets employed and risks assumed remain material to comparability analysis. An upper turnover filter may therefore be applied where it rationally distinguishes companies with materially different scale and economic profiles. Its application is a factual determination and is not open to interference unless perversity is pleaded and demonstrated. The Tribunal's use of the filter consequently raised no substantial question of law, and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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