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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Commercially genuine exclusivity payments, transition-fee reimbursements and upfront discounts made to associated enterprises cannot be disregarded merely because their commercial structure is unusual or their expediency is questioned. Arm's length pricing cannot be fixed at nil without applying a prescribed transfer-pricing method; where the underlying primary adjustment fails, consequential notional interest also fails. Secondary-adjustment provisions do not apply to primary adjustments preceding 1 April 2016. Interest on a foreign-currency associated-enterprise loan is benchmarked at LIBOR plus 80 basis points. For exempt-income disallowance, only income-yielding investments are relevant and sufficient own interest-free funds preclude interest disallowance. Export turnover, TDS credit and education-cess claims were addressed through specified computation, verification and retrospective-amendment principles.
Commercially genuine exclusivity payments, transition-fee reimbursements and upfront discounts made to associated enterprises cannot be disregarded merely because their commercial structure is unusual or their expediency is questioned. Arm's length pricing cannot be fixed at nil without applying a prescribed transfer-pricing method; where the underlying primary adjustment fails, consequential notional interest also fails. Secondary-adjustment provisions do not apply to primary adjustments preceding 1 April 2016. Interest on a foreign-currency associated-enterprise loan is benchmarked at LIBOR plus 80 basis points. For exempt-income disallowance, only income-yielding investments are relevant and sufficient own interest-free funds preclude interest disallowance. Export turnover, TDS credit and education-cess claims were addressed through specified computation, verification and retrospective-amendment principles.
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