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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The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the Transfer Pricing Officer (TPO) as at Arm's Length Price (ALP) u/s 92CA(3) of the Act. The TPO's role is to ensure pricing is at ALP. Documents were submitted and findings from survey proceedings were available to the TPO. Consistency was maintained as no adjustments were made in prior years. The allocation key should not be disturbed. Regarding depreciation on intangible assets, the Tribunal directed the AO to grant depreciation as per previous rulings in the assessee's favor.
The Appellate Tribunal examined Transfer Pricing Adjustment disallowing cost of support services. The cost allocation key based on 'headcount' was accepted by the Transfer Pricing Officer (TPO) as at Arm's Length Price (ALP) u/s 92CA(3) of the Act. The TPO's role is to ensure pricing is at ALP. Documents were submitted and findings from survey proceedings were available to the TPO. Consistency was maintained as no adjustments were made in prior years. The allocation key should not be disturbed. Regarding depreciation on intangible assets, the Tribunal directed the AO to grant depreciation as per previous rulings in the assessee's favor.
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