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 - comparability - under Rule 10B(2)(b), the comparability of an international transaction with an uncontrolled transaction shall be judged, among other factors, with reference to the functions performed, taking into account assets employed or to be employed and risks assumed by the respective parties to the transactions. - AT
TP Adjustment - comparability - under Rule 10B(2)(b), the comparability of an international transaction with an uncontrolled transaction shall be judged, among other factors, with reference to the functions performed, taking into account assets employed or to be employed and risks assumed by the respective parties to the transactions. - AT
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