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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Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous rulings, held that the market value for computing profits from the CPP should be based on the rate at which the State Electricity Board (SEB) supplied power to consumers. The tribunal directed the deletion of the transfer pricing adjustment and allowed the deduction under Section 80IA based on the transfer price of Rs. 8.48 per unit.
Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous rulings, held that the market value for computing profits from the CPP should be based on the rate at which the State Electricity Board (SEB) supplied power to consumers. The tribunal directed the deletion of the transfer pricing adjustment and allowed the deduction under Section 80IA based on the transfer price of Rs. 8.48 per unit.
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