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 - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in manufacturing and selling sanitaryware products. Despite some functional diversity, the Tribunal found the core activities sufficiently similar for comparison purposes. - The Tribunal directed the exclusion of Cera Sanitaryware Limited from the list of comparables. It noted that while the functions performed by Cera Sanitaryware Limited were similar to the Assessee's, the lack of proportionate revenue data for different activities made it unreliable for benchmarking purposes.
TP Adjustment - comparable selection - The Tribunal upheld the inclusion of HSIL Limited in the list of comparables, considering its core business activities in manufacturing and selling sanitaryware products. Despite some functional diversity, the Tribunal found the core activities sufficiently similar for comparison purposes. - The Tribunal directed the exclusion of Cera Sanitaryware Limited from the list of comparables. It noted that while the functions performed by Cera Sanitaryware Limited were similar to the Assessee's, the lack of proportionate revenue data for different activities made it unreliable for benchmarking purposes.
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