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 - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3% Filter - The Tribunal upholds the adoption of Transactional Net Margin Method (TNMM) over Resale Price Method (RPM), citing subsequent TNMM usage and functional comparability. It supports the introduction of new comparables and the rejection of the 3% filter due to marketing intensity. The Tribunal confirms the deletion of additions based on selected comparables' margin comparison with the appellant.
TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3% Filter - The Tribunal upholds the adoption of Transactional Net Margin Method (TNMM) over Resale Price Method (RPM), citing subsequent TNMM usage and functional comparability. It supports the introduction of new comparables and the rejection of the 3% filter due to marketing intensity. The Tribunal confirms the deletion of additions based on selected comparables' margin comparison with the appellant.
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