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 - comparable selection - The High Court upheld the ITAT's decision, emphasizing the principle of comparing entities with similar characteristics. It acknowledged the appellant's argument that the comparables had been in business for many years, whereas the appellant had only started operations recently. The High Court agreed that comparing entities with different operational histories was inappropriate. It noted that the appellant's expenses were similar to those of subsequent years when sales had increased, indicating business stabilization.
TP Adjustment - comparable selection - The High Court upheld the ITAT's decision, emphasizing the principle of comparing entities with similar characteristics. It acknowledged the appellant's argument that the comparables had been in business for many years, whereas the appellant had only started operations recently. The High Court agreed that comparing entities with different operational histories was inappropriate. It noted that the appellant's expenses were similar to those of subsequent years when sales had increased, indicating business stabilization.
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