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 Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the purchase of development rights, including the applicability of transfer pricing provisions to transactions capitalized in the books of accounts and not directly affecting the profit and loss account. One of the most contentious issues was the use of circle rates for determining the arm's length price of the transaction. Circle rates, usually used for stamp duty purposes, were considered by the TPO as a benchmark for the arm's length price. - The tribunal concludes that the omission of clause (i) of section 92BA of the Income Tax Act, 1961, should be treated as if the clause had never been part of the statute, thereby precluding transfer pricing adjustments on specified domestic transactions from the date of omission.
Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the purchase of development rights, including the applicability of transfer pricing provisions to transactions capitalized in the books of accounts and not directly affecting the profit and loss account. One of the most contentious issues was the use of circle rates for determining the arm's length price of the transaction. Circle rates, usually used for stamp duty purposes, were considered by the TPO as a benchmark for the arm's length price. - The tribunal concludes that the omission of clause (i) of section 92BA of the Income Tax Act, 1961, should be treated as if the clause had never been part of the statute, thereby precluding transfer pricing adjustments on specified domestic transactions from the date of omission.
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