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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Income accrued in India - testing and other services - exception curved out to Article 12(5) of the India-Finland DTAA that when the fees is paid for technical services which are performed within a contracting state does not apply as the payment in question was made for the test results which were used within India. though the process of testing may have been conducted outside India but the payment in question is not for the process but was for the results of testing - taxable in India
Income accrued in India - testing and other services - exception curved out to Article 12(5) of the India-Finland DTAA that when the fees is paid for technical services which are performed within a contracting state does not apply as the payment in question was made for the test results which were used within India. though the process of testing may have been conducted outside India but the payment in question is not for the process but was for the results of testing - taxable in India
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