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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TP adjustment - AO/TPO has not followed direction of DRP - As per section 144C(13) the AO is bound to pass the final assessment order in conformity with the direction of the DRP and there is no scope for any deviation from the direction - directed to comply with the direction of the learned DRP on the issue of adjustment to the International transaction of import of finished goods
TP adjustment - AO/TPO has not followed direction of DRP - As per section 144C(13) the AO is bound to pass the final assessment order in conformity with the direction of the DRP and there is no scope for any deviation from the direction - directed to comply with the direction of the learned DRP on the issue of adjustment to the International transaction of import of finished goods
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