9911796707
| TMI General Search |
|
Advanced Search Options
Showing 61 to 80 of 516 Records Search Text: service tax medical transcription |
| Search Results |
| Acts / Rules (1) Articles (2) Case-Laws (487) Circulars (19) Forum (1) Highlights (1) News (2) Notifications (3) |
|
2023 (4) TMI 76 - ITAT BANGALORE TP Adjustment - Comparable selection - Assessee is engaged in the business of providing Information Technology ( IT ) support services / software development services and IT Enabled services ( ITES ) to its AEs - HELD THAT:- Exclusion of M/s Genesys International Corporation Ltd, M/s Infosys Ltd. as functionally dissimilar. ICRA Techno Analytics Limited - As the method as to how that RPT filter is considered by the TPO / CIT(A) needs factual verification we remit the issue of exclusion of M/s. I... ... ...
2022 (4) TMI 1331 - DELHI HIGH COURT TP Adjustment - comparable selection - ITAT has erred in excluding M/s Eclerx Services Pvt. Ltd, TCS E-Serve Ltd, BNR Udyog Ltd. and Excel Infoways Ltd as comparables for determining arm s length price in the case of the respondent - HELD THAT:- It is settled law that exclusion or inclusion of one or other comparable would by itself not constitute a question of law unless it is shown that there are important functional dissimilarities or vital material facts which go to the root of profitability... ... ...
2022 (2) TMI 177 - ITAT MUMBAI Disallowance of Equity Stock Options ( ESOP ) expenditure - eligible criteria for acquiring the shares under the ESOP - HELD THAT:- In order to be eligible for acquiring the shares under the ESOP, the concerned employees are obliged to render services to the company during the vesting period as given in the scheme. On the completion of the vesting period in the service of the company, such options vest with the employees. The options are then exercised by the employees by making application to t... ... ...
2019 (12) TMI 1318 - ITAT COCHIN TP Adjustment - prior period income of the company in the software development and ITeS segment for determination of ALP - HELD THAT:- There is no dispute that the amount is the prior period income relevant to the assessment year 2009-10. All the expenses relating to this income had already been accounted for in the earlier assessment year 2009-10. Being so, this amount cannot be considered as operational income of the current assessment year 2010-11. Being so, the DRP is justified in observing ... ... ...
Clarification on doubts related to supply of Information Technology enabled Services (ITeS services) The circular issued by the Department of Taxes, Manipur, clarifies the classification of Information Technology enabled Services (ITeS) under the Goods and Services Tax (GST) framework. It distinguishes between ITeS providers acting on their own account and those acting as intermediaries. The circular outlines three scenarios: ITeS suppliers providing services on their own account are not intermediaries; those facilitating supply for foreign clients are intermediaries; and mixed service providers' status depends on specific circumstances. It also states that non-intermediary ITeS providers can qualify for export benefits if they meet certain criteria under the IGST Act.
2018 (4) TMI 1064 - ITAT MUMBAI TPA - Comparable selection criteria - Functional profile of the Assessee - Held that:- Assessee could be said to be engaged in the business of being a captive contracts services provider rendering services to its AE’s which are in the nature of providing back office support services which are low end in nature, thus companies functionally dissimilar with that of assessee need to be deselected from final list.... ... ...
2018 (4) TMI 878 - ITAT DELHI Transfer pricing addition - comparable selection criteria - functional similarity - Held that:- The assessee is engaged in the business of development of computer software for its Associated Enterprises (AEs), thus companies functionally dissimilar with that of assessee need to be deselected from final list.... ... ...
2018 (4) TMI 1755 - ITAT BANGALORE TP Adjustment - determination of Arm s Length Price in respect of international transaction of rendering of Software Development Services and Information Technology Enabled Services by the Assessee to its holding company - Comparable selection - HELD THAT:- Assessee is a company engaged in the business of providing contract Software Development Services (SWD Services) and providing Information Technology Enabled Services (ITES) to its holding company in Netherlands BV as a captive service provid... ... ...
2017 (12) TMI 924 - ITAT DELHI TPA - selection of comparable - Held that:- Assessee is into IT Enabled Back Office Medical Transcription services as part of its business operation, providing medical transcription services exclusively to HCR Information Corporation USA, the ultimate holding company of The taxpayer - HBTS, thus companies functionally dissimilar with that of assessee need to be deselected from final list of comparability Entitled to deduction under section 10A - Held that:- Since DRP has given categoric directio... ... ...
2017 (11) TMI 526 - ITAT PUNE TPA - Comparable selection criteria - Held that:- : The assessee company is engaged in the business of designing and developing softwares. The assessee is also providing support services through Call Centre. The assessee is providing Information Technology Services (ITS) and Information Technology Enabled Services (ITES) to its holding company M/s. Parametric Technology Corporation (PTC USA). Thus, the assessee is a captive service provider thus functionally dissimilar companies need to deselect... ... ...
2017 (6) TMI 1179 - ITAT DELHI TPA - selection of comparable - Held that:- American Express group is engaged in the business of rendering travel related services of American Express card, travellers cheques and travel services, financial advisory services and international banking services throughout the world, thus companies functionally dissimilar with that of assessee need to deselected from final list. A comparable cannot be included in the comparability analysis for comparing the PLI of the assessee for the reason of non... ... ...
2017 (3) TMI 1689 - ITAT DELHI TPA - comparable selection - Held that:- The assessee company was engaged in providing data collection, web services, information research and related support services to its associated enterprises (AE), thus companies functionally dissimilar with that of assessee need to deselected from final list. Working capital adjustment - Held that:- In the case of the assessee company, the working capital adjustment has been allowed in assessment year 2008-09 and 2012-13 and there has been no change in th... ... ...
2017 (3) TMI 475 - ITAT AHMEDABAD Revision u/s 263 - Penalty proceedings u/s 271(1)(c) - assessment/reassessment proceedings in respect of deduction under S.10B - revision u/s 263 - Held that:- In the instant case, there is no order in so far as penalty proceedings are concerned. The proceedings in respect of assessment and penalty are different and distinct notwithstanding the precondition that later has to be initiated in the course of former proceedings. Though expression ‘assessment’ is used in the Act with different meaning... ... ...
2016 (4) TMI 1478 - ITAT DELHI TPA - comparable selection - selection criteria - Held that:- The Appellant provides mapping services mainly to COWI A/S, which is 59% of the total turnover of the Appellant. As per the functional analysis documented in the Transfer Pricing documentation, the Appellant can be is characterized as a service provider, which assumes less than normal risks associated with carrying out such business, companies functionally dissimilar with that of assessee need to be deselected from final list of compa... ... ...
2013 (11) TMI 216 - ITAT BANGALORE Transfer Pricing Adjustment - Rejection of two comparable companies - Held that:- in the period under consideration, comparable company was outsourcing most of its work whereas the assessee was carrying out the work by themselves - There is no dispute to the fact that the assessee providing business process outsourcing services to its AEs and operating in the ITES sector has no software product intangibles - a company having unique software developed in house which also renders specialized servi... ... ...
2024 (12) TMI 432 - DELHI HIGH COURT TP Adjustment - comparable selection - whether Infosys BPO Ltd. was required to be excluded as a comparable entity for conducting the bench marking analysis for determining the ALP u/s 92CA? - HELD THAT:- In the present case, as noted, this court had examined the question of comparability of entities on merit and in accordance with the statutory framework u/s 92CA of the Act read with Rule 10B (1) (e) of the Income Tax Rules, 1963. It is also material to note that the question of suitability to ... ... ...
2021 (3) TMI 928 - ITAT, BANGALORE TP Adjustment - comparability of R Systems International Limited - HELD THAT:- R Systems International Ltd. is following the calendar year i.e. 1st Jan. to 31st Dec for maintaining their accounts, whereas the assessee follows 1st Apr. to 31st March, still it could be a comparable to the assessee s case and be included as a comparable in the list of comparables as decided by the Tribunal in the case of Indecomm Global Services India Pvt. Ltd.[ 2019 (12) TMI 78 - ITAT BANGALORE] . Accordingly, we ... ... ...
2021 (2) TMI 877 - ITAT MUMBAI TP Adjustment - Adopting the Transactional Net Margin Method (TNMM) for benchmarking its International transactions and Operating Profit/Total Cost (OP/TC) as the PLI - Comparable selection - HELD THAT:- Assessee is into international transactions of provision of business support services to its group entities, thus companies functionally dissimilar with that of assessee need to be deselected from final list. As three companies which were included by the TPO/DRP in the final list of comparables ... ... ...
2020 (8) TMI 10 - ITAT MUMBAI TP Adjustment - comparable selection - functional similarity - HELD THAT:- Assessee is engaged in providing IT services and solution that helps clients plan, build, support and manage their IT infrastructures, thus companies functionally dissimilar with that of assessee need to be deselected. Extraordinary event such as merger/amalgamation would have an impact/effect on the profitability. Since Accentia Technologies Ltd., Cosmic Global Ltd., Mold Tek Technologies Ltd., Acropetal Technologies Ltd... ... ...
The circular from the Himachal Pradesh Excise and Taxation Department addresses clarifications regarding the supply of Information Technology enabled Services (ITeS) under GST law. It distinguishes between suppliers acting on their own account versus those acting as intermediaries, as defined in the Integrated Goods and Services Tax Act. Three scenarios are outlined: suppliers providing services independently, those facilitating services for clients, and those doing both. The determination of whether a supplier is an intermediary depends on the specifics of each case. Non-intermediary suppliers can qualify for export of services benefits if they meet certain criteria. The circular is effective from July 18, 2019.
|
