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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Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer attributed 25% of the profit to the PE in India, only one contract was thoroughly examined, neglecting others. The Tribunal found this attribution to be arbitrary and lacking proper analysis. The estimation of profit rate at 10% was deemed unjustified, especially considering the Assessee's evidence of a lower global profit rate. The Tribunal, therefore, directed a de novo adjudication by the Assessing Officer after considering all relevant factors and providing a reasonable opportunity to the Assessee.
Income deemed to accrue or arise in India - Attribution of Profit to permanent establishment (PE) in India - The Tribunal observed that while the Assessing Officer attributed 25% of the profit to the PE in India, only one contract was thoroughly examined, neglecting others. The Tribunal found this attribution to be arbitrary and lacking proper analysis. The estimation of profit rate at 10% was deemed unjustified, especially considering the Assessee's evidence of a lower global profit rate. The Tribunal, therefore, directed a de novo adjudication by the Assessing Officer after considering all relevant factors and providing a reasonable opportunity to the Assessee.
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