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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Transfer Pricing Adjustment on Delayed Sales Proceeds - Normally there would be a difference between the lending rate and borrowing rate in each country. Some authors and writers suggest that the average or mid-point between the two should be taken. However, others like Klaus Vogel have suggested that economic purpose and substance of the debt-claim or debt for which granting of credit calls for the lending rate would be determinative. - The ITAT observed that, we do not deem it necessary to enter into this controversy and express our view as regards the same. - The ITAT held that the interest rate on delayed sales proceeds should be based on the currency in which the loan is to be repaid, favoring the application of LIBOR over the Indian Prime Lending Rate (PLR).
Transfer Pricing Adjustment on Delayed Sales Proceeds - Normally there would be a difference between the lending rate and borrowing rate in each country. Some authors and writers suggest that the average or mid-point between the two should be taken. However, others like Klaus Vogel have suggested that economic purpose and substance of the debt-claim or debt for which granting of credit calls for the lending rate would be determinative. - The ITAT observed that, we do not deem it necessary to enter into this controversy and express our view as regards the same. - The ITAT held that the interest rate on delayed sales proceeds should be based on the currency in which the loan is to be repaid, favoring the application of LIBOR over the Indian Prime Lending Rate (PLR).
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