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 - Non-Resident - taxability of interest on Income Tax Refund - Contrary decisions of different High courts - As in case of ACIT Vs. Clough Engineering Ltd. [2011 (5) TMI 562 - ITAT, DELHI] a view favourable to the assessee has been taken. However, in case of B.J. Services Co. Middle East Ltd. [2015 (5) TMI 1036 - UTTARAKHAND HIGH COURT] the Hon’ble HC, while examining pari materia provision contained in Article 12(6) of India-UK Treaty has held that interest on income tax refund is taxable as business profits under Article 7 of the treaty. In our humble opinion, the decision of the Hon’ble Uttarakhand High Court will carry greater precedentiary value. - AT
Income accrued in India - Non-Resident - taxability of interest on Income Tax Refund - Contrary decisions of different High courts - As in case of ACIT Vs. Clough Engineering Ltd. [2011 (5) TMI 562 - ITAT, DELHI] a view favourable to the assessee has been taken. However, in case of B.J. Services Co. Middle East Ltd. [2015 (5) TMI 1036 - UTTARAKHAND HIGH COURT] the Hon’ble HC, while examining pari materia provision contained in Article 12(6) of India-UK Treaty has held that interest on income tax refund is taxable as business profits under Article 7 of the treaty. In our humble opinion, the decision of the Hon’ble Uttarakhand High Court will carry greater precedentiary value. - AT
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