Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
The ITAT Hyderabad upheld the Corporate Guarantee Commission at 0.53% for guarantees to foreign AEs, rejecting the AO's 1.8% rate. The tribunal determined the pro rata guarantee at 30.50% of a $10 million loan balance. The CIT(A) classified corporate guarantees as international transactions and set the commission at 0.53%. Interest on trade receivables was benchmarked at 6% SBI rate. The tribunal remanded R&D, Head Office, and Marketing expenses issues back to the AO/TPO for fresh assessment, citing a violation of natural justice. The tribunal directed the assessee to provide segmental accounts for accurate benchmarking. The tribunal excluded certain comparables based on RPT filter agreement.
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