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Try out our Premium Member services: Free for one month and pay only if you like it. DR Date of Hearing The following grounds have been raised in the present appeal: The appellant craves leave to add, amend, alter or vary, any of the aforesaid grounds of appeal before or at the time of hearing of the appeal.
Addressing the grounds raised, it was submitted by the Ld. AR that considering the peculiar facts and circumstances of the case although the assessee is confident that it would succeed in its prayer for seeking inclusion of comparables which have not been included and also seeking the exclusion of comparables which have been wrongly included and thus as far as the addition sustained by way of making an adjustment is concerned the judicial precedent is predominantly in its favour.
However, it was his submission that it would be appropriate to seek to first press for adjudication on the issues addressed by Ground No. The said request made right at the outset was objected to by the Ld.
Accordingly it was his stand that the issue need not be restored and the assessee be directed to argue all its grounds.
Responding to the said objection the Ld. Advocate relying upon the Chart of Issues filed, stated that in the peculiar facts and circumstances of the case, he would have no objection to address the comparables which are sought to be included by the TPO and the comparables the exclusion of which has been sought by the assessee.
However, in order to be fair to the Revenue as well as tax payer it was highlighted that wrong characterisation of the taxpayer would impact the subsequent years also and since this would be a continuing issue in the subsequent years also the position on facts should be addressed in the initial years itself.
Thus in the circumstances it was clarified that first his endeavour would be on the basis of material on record to show that there is flaw in the characterization of the assessee as a result of this the entire exercise of selection of comparables has become skewed.
In the eventuality the issue is considered to be not allowable, it was stated that he is ready to address the comparables and is confident that he would be able to demonstrate that the comparables retained by the tax authorities and excluded by them on facts and law is contrary to accept judicial precedents.
Thus, it was his submission that the argument that the entire exercise of selection of comparables would stand demolished. Considering the submissions made by the Ld. DR submitted that he would have no objection to the prayer for remand subject to the assessee demonstrating how characterisation of the taxpayer has wrongly been done.
Page 4 of 21 I. In the said background the Ld. Attention was invited to specific page 66 so as to highlight that the TPO has considered that the taxpayer was engaged in providing "Investment and other financial advisory". Referring to the companies mentioned at serial No.
Similarly the company mentioned at Sl. Their selection when considered with the profile of the assessee it was submitted is incorrect.
The remaining companies which have been wrongly included namely Aptico Ltd. Thus since the characterization itself is incorrect in the circumstances the assessee is confident that in fact each of the comparable selected, it can be successfully demonstrated as having been wrongly selected.
Thus the prayer for restoring the issue back for a proper appreciation has been made. The following specific ground of objections were raised in iv and v: Specific page to was referred to and specific emphasis was laid on para B of the same in order to emphasize the nature of the activity.
Page 6 of 21 I.
For ready- reference, the relevant extract from the said page is reproduced hereunder: The companies listed in Schedule 1 to this Agreement "Seller" ; and 2. Attention was also invited to pages 32 to 84 of the paper book which is the transfer pricing documentation.
Specific attention was invited to page 38 and 39 of the same so as to highlight the Objective and the Company Overview which would throw light on the activities of the tax payer.
The relevant extracts of the same are reproduced hereunder from the said pages in the paper book: The group provides advice and services that enable companies, governments and international organizations to accelerate Page 7 of 21 I.public works department (r & b) RULES OF ENLISTMENT OF CONTRACTORS IN PWD Title: These rules shall be called the “Rules of Enlistment of Contractors in PWD, ” and shall come into force with effect .
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Corporate Profile; Chairman's Message; Board Of Directors; Employees; Committee. public works department (r & b) RULES OF ENLISTMENT OF CONTRACTORS IN PWD Title: These rules shall be called the “Rules of Enlistment of Contractors in PWD, ” and shall come into force with effect from the date of notification in Tripura Gadget.
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