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 - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator (PLI). The taxpayers argued that such losses are non-operating, supported by the Safe Harbor Rules and previous judicial decisions. However, the tribunal, aligning with the CIT(A) and TPO, concluded that forex losses related to business activities should be considered operating.
TP Adjustment - The main contention was whether forex losses should be considered as non-operating or operating for the purpose of computing the Profit Level Indicator (PLI). The taxpayers argued that such losses are non-operating, supported by the Safe Harbor Rules and previous judicial decisions. However, the tribunal, aligning with the CIT(A) and TPO, concluded that forex losses related to business activities should be considered operating.
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