IT: Where in search no discriminating material was found which would suggest unexplained income or there was no recovery of cash or amount from assessee, levy of penalty would be set aside
Thursday 7 November 2013
Deemed dividend is when shareholders receive loan from a Co. and not vice-versa
IT: Where assessee-company received loan from another company and assessee was not a shareholder in said company, deeming provisions of section 2(22)(e) were not applicable to impugned transaction of loan
Finance Minister P Chidambaram to address industry bodies on service tax amnesty scheme
Aiming to garner higher revenue from indirect taxes, Finance Minister P Chidambaram will address industry bodies at Chennai, Delhi and Mumbai on Voluntary Compliance Encouragement Scheme 2013.
VCES had been introduced with effect from May 10, 2013 as a one time amnesty scheme for paying service tax dues for the period October 1, 2007 to December 31, 2012 without interest and penalty.
"The Union Finance Minister P Chidambaram will address trade/industry/service associations and Chambers of Commerce &Industry at Chennai, Delhi and Mumbai on Voluntary Compliance Encouragement Scheme (VCES) 2013," the Finance Ministry said in a statement today.
The minister will address the representatives of various trade associations and Chambers on VCES in Chennai on November 9, in Delhi on November 11 and in Mumbai on November 14.
The services sector contributes about 65 per cent to the Gross Domestic Product ( GDP) of country but the number of service tax payers is quite less.
Recently, Chidambaram had said that out of the 17 lakh registered assesses under Service tax, only seven lakh were filing returns.
"Many have simply stopped filing returns. We cannot go after each of them. I have to motivate them to file returns and pay the tax dues. Hence, I propose to introduce a one-time scheme called 'Voluntary Compliance Encouragement Scheme'," the Finance Minister had said in his Budget speech.
Government has set indirect tax collection target of Rs 5.65 lakh crore for 2013-14, up from Rs 4.73 lakh crore in the last fiscal.
New Indian Wheat Supply Won't Threaten Australian Premiums
India's move to cut wheat export prices has curbed a rally in U.S. wheat futures and cheap cargoes are expected to enter the market after tenders this month, but that is unlikely to erode premiums for higher-quality Australian supplies.
Traders say the Indian supplies will go largely into animal feed or to fill demand for lower-quality milling wheat, while Australian wheat will take care of higher-end demand for making noodles, bread and cakes.
Expectations that India would open the floodgates for wheat have reversed gains in Chicago Board of Trade futures, which have lost more than 8 percent since hitting a near-five-month high of $7.11-1/4 a bushel on Oct. 21.
The spot-month December contract was trading at $6.54-1/4 a bushel at 0640 GMT on Thursday.
"Australia is not expected to have large volumes of feed wheat this year although they have yet to go through the crucial harvest season," said one Singapore-based grains trader. "Indian wheat is going to be selling at a discount to U.S. soft red winter wheat and Black Sea wheat."
Australian wheat prices have held up thanks to strong demand led by China, which saw some 16 percent of its crop damaged by adverse weather earlier this year.
Australian prime wheat was quoted this week around $290 a tonne, free on board, while prime hard wheat with 13 percent protein was being offered around $351 a tonne.
"They probably won't steal a lot of business away from Australia. Indian wheat will enter the feed market while even our lower-quality Australian standard wheat will be bought by flour millers," said Andrew Woodhouse, a grains analyst at Advance Trading Australasia.
Source:- reuters.com
Top Iron Ore Exporter Goa Wants To Halve Fresh Output
India's top iron ore exporting state of Goa hopes the Supreme Court will soon lift a year-long ban on mining but aims to rein in production to ease pressure on roads and infrastructure, the state's regulator of mining licenses said on Thursday.
Bans in Goa and an adjacent state over the past two years have cut to a trickle India's exports to top market China, with shipments falling 75 percent to just over 8 million tonnes over January to September, Chinese data show.
The top court, which suspended mining last year after a federal panel found several violations, such as firms mining without licences or outside lease areas, is expected to rule on Monday whether mining can resume, Prasanna Acharya told Reuters.
"It's up to the court to decide, but we have proposed a cap of 20 million tonnes on fresh extraction, compared with about 42 million earlier," said Acharya, head of the government body that grants mineral licenses in India's southern state of Goa.
"We are seeking an overall cap of 45 million tonnes for exports, including fresh extraction and recovery from dumps."
Goa, which formerly exported its entire output of iron ore, has more than 700 million tonnes of dumps, accumulated over years and containing recoverable ore, a state mineral policy document says.
The dumps typically consist of small quantities of ore that cannot be retrieved easily or economically. They were stored until "technology became available whereby the ore could be recovered economically," according to the policy document.
Some analysts see a gradual recovery in Indian exports over the next two years, limiting the impact on the global supply chain and on prices, although the pace will be modest and far from a record of more than 117 million tonnes set in the fiscal year through March 2010.
In the third-biggest exporting state of Karnataka, adjacent to Goa, shipments had been banned since July 2010. Although a 2011 ban on mining was revoked in April, operations have resumed in only about a dozen of the state's 115 mines.
Many Karnataka miners still await forest clearances, the renewal of mining licenses and removal of other obstacles. Miners in Goa, too, fear months could pass before they can begin operations, even if the top court orders resumption soon.
Source:- in.reuters.com
Outlook On Textile Exporting Companies: India Ratings
India Ratings & Research (Ind-Ra) expects the financial metrics of garment manufacturers to improve during FY14 (year end March), which could be one of the key drivers for a positive rating action. "A combination of improving textile and apparel demand from large markets, benefits accruing from a depreciating rupee and structural changes in competing markets like China and Bangladesh have resulted in the improved performance of and stronger order book visibility for Indian exporters.
The trends are seen to sustain in the short-to-medium term", says Tanu Sharma, Associate Director, Corporates, India Ratings & Research. Most garment exporters are therefore running on full capacity and also outsourcing manufacturing on a job work basis as order books are growing ahead of the peak festive season (December). During April-September 2013, garment exports grew 13 percent yoy in US dollar (USD) terms reaching USD6.5bn while growth in rupee terms was even higher at 18 percent yoy. Rupee depreciation has improved the competitiveness of Indian exporters in global textile trade against China, Bangladesh and Vietnam. India's competitiveness has also has benefited from the appreciation of the Chinese yuan against USD and rising labour cost in China.
Large international buyers have also diverted orders to India from Bangladesh on account of wage protests in September 2013 and a factory accident in April 2013. Shahi Exports Private Limited ('IND A-'/Stable), a leading garment exporter, registered revenue (unaudited) of INR18.65bn, up 25 percent yoy, and has an order book of INR12.75bn to be executed in the next three months.
Eastman Exports Global Clothing Private Limited was upgraded on 21 October 2013 to 'IND A' from 'IND A-', primarily due to a significant improvement in revenue with the addition of new clients and a strong order book from them, among other positive rating drivers.. Strong revenue growth in FY14 and earnings are likely to improve the credit metrics of garment exporters. However, the challenge for exporters is to manage liquidity amid increasing volumes coupled with a long working capital cycle and the consequent higher use of working capital limits, which is a characteristic of the textile export business.
Source:- moneycontrol.com
India's Oil Companies Buying Dollars In Markets Again: Mayaram
India's state-run oil companies have started buying 30-40 per cent of their dollar demand in markets instead of the special window provided by the Reserve Bank of India (RBI), television channels reported on Thursday, quoting economic affairs secretary Arvind Mayaram.
A return to sourcing some of their dollar needs from spot markets would mark a wind down of a key emergency measure imposed by the RBI in late August, when the rupee was tumbling to record lows against the dollar.
The RBI then directed India's three state-run oil companies to source dollars directly from a special window provided by the central bank in a bid to ease selling pressure on the local currency.
Oil companies are the biggest buyers of dollars in markets, averaging around $300-350 million a day, according to traders' estimates.
Neither TV channel showed Mayaram's full remarks.
Although the move helped the rupee recover from a record low of 68.85 in late August, it has weighed in the near term on India's currency reserves of $283 billion, which are enough to cover only seven months of imports.
Under the swap window, oil companies were buying dollars through forward contracts from the central bank at market-determined rates with a promise to pay back those dollars to the RBI.
The window would have had to end sometime in November given the RBI was offering a 3-month dollar swap facility to the oil refiners, one official with direct knowledge of the arrangements told Reuters.
Still, few analysts expect the rupee to slump should the RBI close its dollar window completely, given that the Federal Reserve's delay of its planned withdrawal of monetary stimulus has sparked a rally in Indian markets.
Foreign institutional investors have bought nearly $4 billion in domestic shares since the Fed announced the delay in mid-September, pushing the BSE sensex to a record high last week.
Banks in India have also raised $15.1 billion in loans and funds from citizens abroad ever since the RBI started subsidising some of the exchange costs.
The rupee is expected to stabilize in 1-2 days as state-run oil dollar demand gets absorbed by markets, television channel CNBC-TV18 also quoted Mayaram as saying.
Bank of America-Merrill Lynch had advocated the RBI close the window, arguing it had already been factored into markets.
"We believe the time is right for RBI to start tapering its swaps with oil companies to fund oil imports as the markets are already pricing these in," the US investment bank said in a report on Tuesday.
"It is scarcely possible to fund net oil imports averaging $8-10 billion a month with FX reserves of about $280 billion."
The rupee was trading at 62.58 late on Thursday, weaker than its previous close of 62.39/40.
It has rebounded around 10.3 per cent since hitting a record low of 68.85 on August 28.
Still, a Reuters poll on Thursday showed it will likely struggle to recover any more ground over the next 12 months due to uncertainty around upcoming elections, the country's external deficit and the impact of the possible tapering in the Federal Reserve's stimulus programme.
Source:- timesofindia.indiatimes.com
Central Bureau of Narcotics is not an enterprise
CL: Where opposite parties were only agencies appointed by Government of India to ensure that illegally cultivated poppy seeds were not smuggled into India, they could not be compared to commercial organization and did not qualify to be an enterprise within meaning of section 2(h) and provision of section 4 related to abuse of dominant position could not be applied to information received against opposite parties
Packaged Food Import Becomes A Sticky Issue
The Food Safety and Standards Authority of India (FSSAI) has put its foot down and said “labelling requirements will not be relaxed” for any packaged food supplier, as these are very “sensitive” products. It maintained that the law mandates printed or inseparable labelling on such products.
“The law of the land is valid for everyone — for domestic suppliers as well as importers — and all are expected to follow it. A regulator’s duty is to implement the law and not violate it…Food is so sensitive and there is no question of relaxing the requirements for pre-packaged food products,” FSSAI’s chief executive officer, Dillip Kumar Samantaray, told Business Standard.
This comes in the wake of several containers of packaged food products carrying imported chocolates, crispies, gourmet cheese, olive oil, biscuits, noodles, pasta, jams, honey, oats and sauces, etc, being recently blocked at various ports and airports across the country, in the absence of a clearance from FSSAI. The regulatory agency, which supervises import of food items to ensure quality, refused permission by citing the labelling requirements in the Food Safety and Standards Act of 2006, which took effect in 2011.
According to Samantaray, a 1982-batch IAS officer, these products were refused permission during visual inspection to check the labelling requirements, among other things. He said most of these products were carrying stickers with various information, whereas the law says stickers are only allowed to differentiate between vegetarian and non-vegetarian products, and to specify the name and address of the importer. “The law of the land requires all other information to be printed on the pack,” Samantaray insisted.
He said food was a sensitive commodity and products such as jams and chocolates were mostly consumed by children. So, quality and specifications could not be compromised. “If domestic manufacturers export products to other countries, they are required to abide by the law of that country. Then why should India not ensure the health of its citizens?” asked Samantaray.
When asked why the sudden stringency, when products with deficient stickers had been available in Indian markets for a long time, the regulator said, “India before 1947 was colonial, so should we continue to be like that even now?” He said products had been barred from entry in the past two years as well.
October-December being the festival season, the blocking of consignments might have impacted the business more than usual. Government sources indicate packaged foods worth Rs 750-1,000 crore was stuck at various ports and airports across the country.
Importers, irked by the lacklustre Diwali sales, say if the issue is not sorted soon, it could impact business during Christmas and New Year, too. About 50-55 per cent of packaged food imports in India happen during the festive season, since it is utilised mainly for gifting, apart from consumption.
Amit Lohani, convenor, Forum of Indian Food Importers, says they’ve already made numerous representations to FSSAI, to resolve the issue. "On October 31, FSSAI came out with a notification agreeing to one of our demands, which is to allow the food safety logo on a sticker. This is with immediate effect," Lohani, who imports Danish cookies, meats, beer and coffee, among other products, said.
Samantray confirmed FSSAI had received representations from various companies as well as industry bodies. It had responded, explaining its stand. Sources say some countries backing the importers have also approached the ministry of external affairs and the ministry of health.
Says Saloni Nangia, president, Technopak Advisors; "The FSSAI's move to enforce labelling standards is a step in the right direction. India, for long, has been a dumping ground for products well past their sell-by-date. Now, there will be some accountability. Product quality is compromised with the use of stickers. FSSAI is attempting to stop that."
Source:- business-standard.com
India's Gold Imports Likely To Drop 41% To 500 Tonnes This Fiscal Year: Mmtc
Metals and Minerals Trading Corporation of India (MMTC Ltd)- the largest player in the country’s bullion trade expects the gold imports by the country during this fiscal year to drop significantly over the previous year. The total gold imports by the country may come down to under 500 tonnes, mainly due to the stringent import restrictions.
Gold imports into the country plunged drastically during recent months. India’s gold imports during the initial six months (April ’13 to Sep ’13) of the current fiscal year totaled 400 tonnes. The September gold imports were as low as 11.14 tonnes. The rise in imports during the festive season lifted the October imports to 23.5 tonnes.
MMTC had earlier announced that it would cut volume of gold imported for domestic consumption by 30%. According to MMTC, even if monthly gold imports remain at 20 tonnes for the rest of the fiscal, the total imports would remain under 500 tonnes. If the muted festive demand witnessed during the Dhanteras and Diwali are any indication, the gold imports are likely to fall further.
The largest public sector trading body in the country also believes that there is no need of any further tightening of gold import rules by the country. The existing curbs are sufficient to bring down the total gold imports in 2013-’14 by 41% as against 850 tonnes import during last year.
Source:- metal.com
Auto Import Expo Hits The Road On Nov 25
The event will be held at the Government Complex Building on Chaengwattana Road from November 25 to December 1. It overlaps with the Thailand International Motor Expo, the other major auto show organised by Inter-Media Consultants, which will be held from November 28 to December 10 at Muangthong Thani.
Grand Prix International senior vice chairman and organiser of the Auto Import Expo Jaturont Komolmis said the company decided to stage this additional event due to the success of the Bangkok Import Car and Used Car Show held in mid-2013.
"Due to the positive response from car dealers and other exhibitors, as well as visitors, we decided to organise another auto show that mainly focuses on exclusive imported vehicles to accommodate the growing demand during the year-end period," he said.
According to Jaturont, more than 30,000 people visit the government complex every day, and 10,000sqm of area in Building B will be used for the event.
"We are staging a new event during this period because it is a car-buying season. Meanwhile, a large number of 2014 models are launched during this period," he added.
He said seven to eight imported right-hand-drive models will be exhibited along with a large number of imported models, mostly luxury cars. Auto dealers will offer special promotions to boost sales.
Jaturont said the imported car market had experienced a decline in the past six months, and the event could help boost the market. "There have been positive signs for the imported car market and the event is likely to help rebuild consumer confidence," he added.
Source:- nationmultimedia.com
With markets booming, it is time to clean up your portfolio
Investment experts are asking individual investors to use the booming stock market to get rid of dud stocks and mutual fund schemes in their portfolio. They are also advising investors to rebalance their portfolio to conform to their asset allocation plan, as the share of equity assets in portfolios would have swelled due to the rally in equities.
It is also a perfect occasion to book profits, they added in good measure. The S&P BSE Sensex touched all-time high of 21321 on Sunday during Muhurat Trading. "Many mutual fund investors do not keep track of the performance of their schemes. This is a good time to review the portfolio and get rid of schemes that have yielded poor returns vis-a-vis their counterparts from other fund houses," says Suresh Sadagopan, certified financial planner and founder, Ladder7 Financial Advisories. "You should consider booking profits and exiting some of your equity investments to adhere to your original asset allocation plan," he adds.
Raghvendra Nath, managing director, Ladderup Wealth Management, points out that retail investors tend to hold onto bad investments due to the fear of booking a loss, which prevents them from undertaking the task of portfolio review regularly. Those who have failed to review the portfolio should make the most of the current market surge to eliminate dud stocks and mutual funds, he says.
"If a stock or mutual fund scheme is not doing well, you should get rid of them after a review, instead of waiting for good times to come. For instance, if you had disposed of a bad stock, say, six months ago and replaced it with a performing stock, the latter would have yielded even better returns during this market rally," he explains. Similarly, if you feel your fund manager has been under-performing for a long time, you should sell off the units, irrespective of market conditions.
Experts says investors should evaluate returns from mutual fund schemes over one, three and five years before taking a final decision. "Comparing your fund's returns with its peers' over these three time periods will be an indicator of its utility value to your portfolio," says Harshvardhan Roongta, certified financial planner and CEO of Roongta Securities.
You need to exercise caution while making such comparisons, particularly in case of mutual funds. "Avoid apples-to-oranges comparison. For instance, in the recent times, mid-cap funds have underperformed severely, while largecaps have done reasonably well. Retail investors who own one largecap and one mid-cap fund tend to make the mistake of comparing the two and switching out of the latter.
Instead, they should look at the right indices for benchmarking. In this case, mid-cap should be benchmarked against mid-cap index and large-cap against Sensex or Nifty," adds Nath. Similarly, a comparison between funds in your portfolio bought over different time periods, too, will not be an accurate indicator.
Rather than comparing funds within your portfolio, assess their performance with respect to the category average, benchmark indices and time periods. In addition, find out whether the fund is adhering to its stated objective. "You can scan the reports sent to you and figure out whether the stocks in the portfolio match the objective. For instance, if an infrastructure fund is investing in banking stocks when your intention was to invest in capital goods companies, you may need to re-evaluate your decision to stick to the fund," says Roongta.
RBI asks NBFCs to migrate towards accepting only CTS standard cheques
NBFCs : Migration of Post-Dated Cheques (PDC)/Equated Monthly Installment (EMI) Cheques to Electronic Clearing Service (Debit)
Revised system audit norms for stock Brokers; Exchanges to report major audit observations on quart
SEBI : Annual System Audit of Stock Brokers/Trading Members
RBI releases framework for setting up of wholly owned subsidiaries by foreign banks in India
Banking : RBI Releases Framework for Setting up of Wholly Owned Subsidiaries by Foreign Banks in India
CBDT notifies ‘Archery Association of India’ for purposes of sec. 80G for three assessment years
IT : Section 80G(2)(c) of The Income-Tax Act, 1961 - Deductions - Donations to Certain Funds, Charitable Institutions, etc. - Notified Sports Association or Institution - Archery Association of India
Sec. 41(1) couldn’t be invoked in respect of liability arising out of chit-lien
IT: Where assessee did not claim deduction in respect of liability arising out of 'chit lien' in any assessment year, section 41(1) could not be invoked
SAT rejects allegations of volume manipulation as fluctuations existed when appellant didn’t underta
SEBI : If fluctuations in volume of a scrip existed even during period when appellants dealing in sale and purchase of securities did not execute any trade, charge of volume manipulation of scrip by appellants would be hollow and baseless
Amplify your gains with margin trading
Want to trade in the stock market without having enough resources? Also don't mind taking high risks? Then margin trading may be one option for you. As the name suggests, margin trading is a leveraging mechanism which enables investors to take exposure in the stock market over and above what is possible with their own resources.
However, despite being a good option of trading for the so-called 'bravehearts', you need to tread with caution. That is because while this mechanism increases your buying power, it enlarges your risk as well. In a way, it amplifies your gains and losses in equal proportions.
This explains why it is still not a recommended way of trading, although the lure of big money has always thrown investors into the lap of margin trading. So much so that an increasing number of small investors are now giving in to temptation of this high-risk trading strategy which had traditionally attracted only short-term punters and deep-pocketed investors.
Market regulator Sebi, from time to time, has been prescribing eligibility conditions and procedural details for allowing this facility.
"Sebi has, for instance, set certain criteria for the securities to be eligible for margin trading facility. It has categorized the securities under three groups, namely, Group 1, Group 2 and Group 3. The securities having mean impact cost of less than or equal to 1 and having traded on at least 80 per cent (+/-5%) of the days for the previous 18 months have been categorized as Group 1. A significant point to note is that the facility of margin trading is available only for Group 1 securities," says Mehul Kothari, senior technical analyst, Market Financial Intelligence.
Sebi has also set the eligibility criteria for brokers to provide the margin trading facility to their clients. For instance, currently corporate brokers with a net worth of at least Rs 3 crore are eligible for providing margin-trading facilities to their clients. However, before providing this facility to a client, the member and the client have been mandated to sign an agreement for this purpose in the format specified by Sebi.
It has also been specified that the client shall not avail the facility from more than one broker at any time. Also, at any point of time, the total indebtedness of a broker for the purpose of margin trading shall not exceed 5 times of his net worth. "Besides, the 'maximum allowable exposure' of the broker towards the margin trading facility shall be within the self-imposed prudential limits and shall not, in any case, exceed the borrowed funds and 50% of his net worth. The broker has to also ensure that the exposure to a single client does not exceed 10 per cent of his total exposure," informs Ashish Kapur, CEO, Invest Shoppe India Ltd.
To get a clear picture of how the margin trading mechanism works, consider the following example. Mr X bought 1,000 shares of ABC Ltd at Rs 210 in early 2012, using the margin finance facility. Assuming his broker offered him 50 per cent leverage on the transaction, this would mean that Mr X effectively paid only half the total transaction amount (only Rs 105,000 out of Rs 210,000) at the time of purchase. The balance, however, was borrowed from the broker/bank, which provided the margin finance facility.
This would have been a win-win situation for both the parties involved had the ABC Ltd share price risen to, say, Rs 220 in a week's time. Mr X would have been richer by Rs 10,000 (minus the interest that he would have to pay to the broker/bank for the borrowed money) and the bank/broker would have gained to the extent of the interest amount on the funds borrowed. Mr X's net profit as a percentage of his initial investment of Rs 105,000 would have been an attractive 9.5 per cent, within the short time-frame.
But, in reality, suppose the share price of ABC Ltd did not go that high. In fact, during the crash, it actually dropped to Rs 175. Mr X would then be incurring a loss of Rs 35 per share, exposing his financer to more risk if the share price were to plummet further.
"It is typically during such times that the broker is forced to make margin calls to clients, asking them to either deposit more money into their account or sell some of the securities in their account to meet the margin shortfall," says Kapur.
Now if Mr X failed to make good the margin shortfall, his broker would sell his shares for the stipulated amount in consideration. Thus, apart from losing his investment, Mr X would also stand to lose the opportunity to make any profit in the future, were the share prices to recover.
Re-assessment to make sec. 69 addition quashed as all facts were disclosed in assessment proceedings
IT : Reopening of assessment on ground that assessee had made unexplained investment in purchase of silver sold during year was not justified when assessee had fully and truly disclosed all relevant materials in respect of investment in purchase of silver sold during assessment proceedings
Presumption as to valid service of notice holds good if same is not returned back to department, say
IT: Where revenue dispatched notices under section 143(2) for two assessment year together in same envelope through post, and assessee accepted to have received one, while denied receipt of other one, presumption of service to assessee was to be accepted
DCIT, CC-23, Vs. M/s. Rama Krishna Jewellers, New Delhi C/o M/s. RRA Taxindia, D-28, South Extension, Part-I, New Delhi
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EPFO settles 28% more claims in October month on month
NEW DELHI: Retirement fund body settled 10.21 lakh claims including transfer and withdrawal of Provident Fund in October, which is 28 per cent more than such settlements in September this year.
"The Employees' Provident Fund Organisation (EPFO) settled 10,21,922 claims during the month of October, 2013. This is 28 per cent higher than the claims settled in September, 2013," an official statement said here.
It said 72 per cent of these claims (settled in October) were settled within 10 days while remaining 28 per cent were settled within 30 days.
Besides improving performance on claims front, the body has also reduced the number of grievances considerably. EPFO's efforts in grievance redressal has paid dividends.
The number of complaints in Central Public Grievances Redressal System (CPGRAM) has come down to less than 100.
The number of grievances in Employees Provident Fund internet Grievance System (EPFiGMS) have also got reduced from more than 25,000 to less than 5,500.
During a recent review, EPFO's Central Provident Fund Commissioner K K Jalan observed that 108 offices out of 123 offices of EPFO do not have a single complaint that have been kept pending for more than 30 days.
EPFO recently bagged the Financial Inclusion and Payment System award for the year 2013. It paid more than 93 per cent of claims electronically and more than 99 per cent of pensioners got pension through core banking solution account number as on November 1, 2013.
RBI asks banks to provide TDS certificates in time to their customers
IT : Timely Issue of TDS Certificate to Customers
Full risk bearing Cos. not comparable to an entity bearing limited risk; comparable rejected in TP s
IT/ILT: Where assessee was a limited risk bearing captive software service provider, while analysing arm's length nature of transfer price companies engaged in software product, functionally dissimilar and full-fledged risk bearing entrepreneur companies were to be excluded as a comparable
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