Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
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