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...
AE segmental benchmarking under TNMM requires consideration of segmental results included in the transfer-pricing study and certified information furnished before completion of the transfer-pricing assessment. Neither the Act nor the Rules requires audited segmental accounts; where the AE-segment margin falls within the arm's-length range of selected comparables, rejection on conjectural grounds is unwarranted and the related adjustment is deleted. Ind AS presentation of part of compulsorily convertible debentures as equity does not change their underlying debt character before actual conversion or redemption. Interest remains deductible in principle, subject to verification that no conversion or redemption occurred during the relevant year.
AE segmental benchmarking under TNMM requires consideration of segmental results included in the transfer-pricing study and certified information furnished before completion of the transfer-pricing assessment. Neither the Act nor the Rules requires audited segmental accounts; where the AE-segment margin falls within the arm's-length range of selected comparables, rejection on conjectural grounds is unwarranted and the related adjustment is deleted. Ind AS presentation of part of compulsorily convertible debentures as equity does not change their underlying debt character before actual conversion or redemption. Interest remains deductible in principle, subject to verification that no conversion or redemption occurred during the relevant year.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
