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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Taxability of income in India - Proof of residence - assessee is a non-resident corporate entity incorporated under laws of Mauritius - The Tribunal held that the documentary evidence (TRC, Global Business License) supports the claim under Article 13(4) of the DTAA. The AO did not conclusively prove that control and management were outside Mauritius. The SEBI’s recognition of the assessee as a Foreign Venture Capital Investor and continuous investment activity in India strengthen the claim of genuine business operations. The Tribunal highlighted the sanctity of the TRC and previous rulings that support its acceptance as proof of residence and entitlement to treaty benefits. - The Tribunal directed the deletion of additions made by the AO, asserting the assessee’s entitlement to exemption under Article 13(4) of the India-Mauritius DTAA for LTCG derived from shares acquired before April 1, 2017.
Taxability of income in India - Proof of residence - assessee is a non-resident corporate entity incorporated under laws of Mauritius - The Tribunal held that the documentary evidence (TRC, Global Business License) supports the claim under Article 13(4) of the DTAA. The AO did not conclusively prove that control and management were outside Mauritius. The SEBI’s recognition of the assessee as a Foreign Venture Capital Investor and continuous investment activity in India strengthen the claim of genuine business operations. The Tribunal highlighted the sanctity of the TRC and previous rulings that support its acceptance as proof of residence and entitlement to treaty benefits. - The Tribunal directed the deletion of additions made by the AO, asserting the assessee’s entitlement to exemption under Article 13(4) of the India-Mauritius DTAA for LTCG derived from shares acquired before April 1, 2017.
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