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 - interest charged on foreign currency loan - The Tribunal ruled in favor of the Assessee, finding that the interest charged on the loan to its Associated Enterprise was at an arm's length rate. As a result, the appeal of the Assessee was allowed, and the addition sustained by the CIT(A) was directed to be deleted.
TP Adjustment - interest charged on foreign currency loan - The Tribunal ruled in favor of the Assessee, finding that the interest charged on the loan to its Associated Enterprise was at an arm's length rate. As a result, the appeal of the Assessee was allowed, and the addition sustained by the CIT(A) was directed to be deleted.
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