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 - benchmarking of international transaction of import of raw materials - the TP adjustments in respect of this transaction should be restricted in terms of the corresponding sales made from the imports made from Kimberly group of companies and third party vendors which are held to be not at arm’s length price as per working given by the assessee before the TPO which is extracted by the DRP in para 5.1 at page no.53 as the PLI adopted was profit earned by sales. - AT
TP adjustment - benchmarking of international transaction of import of raw materials - the TP adjustments in respect of this transaction should be restricted in terms of the corresponding sales made from the imports made from Kimberly group of companies and third party vendors which are held to be not at arm’s length price as per working given by the assessee before the TPO which is extracted by the DRP in para 5.1 at page no.53 as the PLI adopted was profit earned by sales. - AT
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