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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Valuation - Where the appellants have received 17% commission from the supplier which is not related to the imported goods but for the goods supplied to the third party and the services rendered by the appellant in India on such goods, the application of the provisions contained under Rule 9(1)(a) is totally misplaced. - AT
Valuation - Where the appellants have received 17% commission from the supplier which is not related to the imported goods but for the goods supplied to the third party and the services rendered by the appellant in India on such goods, the application of the provisions contained under Rule 9(1)(a) is totally misplaced. - AT
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