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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The transaction value has been enhanced under Rule 10(1)(c) of the Custom Valuation Rules, 2007 which clearly deals with lumpsum payment of royalty. There is no justification for addition of 10% of the value of the declared value. - AT
The transaction value has been enhanced under Rule 10(1)(c) of the Custom Valuation Rules, 2007 which clearly deals with lumpsum payment of royalty. There is no justification for addition of 10% of the value of the declared value. - AT
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