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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A binding advance pricing agreement covering the relevant intra-group second line support services prevented disallowance of the related expenditure on business expediency grounds. The Tribunal held that, once a transaction falls within an APA, it binds both the Department and the assessee because the APA process already examines functions, assets, risks, benefit, and cost allocation; that itself establishes business purpose. The Assessing Officer could not ignore the APA and disallow the expenditure under section 37(1), particularly where no reasons were recorded for the disallowance and similar expenditure had been accepted in earlier years. The disallowance was deleted and the assessee's claim was allowed.
A binding advance pricing agreement covering the relevant intra-group second line support services prevented disallowance of the related expenditure on business expediency grounds. The Tribunal held that, once a transaction falls within an APA, it binds both the Department and the assessee because the APA process already examines functions, assets, risks, benefit, and cost allocation; that itself establishes business purpose. The Assessing Officer could not ignore the APA and disallow the expenditure under section 37(1), particularly where no reasons were recorded for the disallowance and similar expenditure had been accepted in earlier years. The disallowance was deleted and the assessee's claim was allowed.
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