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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment for sales and marketing function. Port fee charges paid allowed at cost plus 25% markup as per agreement. No adjustment required for administrative support services provided to AE as margin exceeded arm's length price. Addition for brokerage on program trades disallowed as direct third-party transactions without benefitting AEs. Disallowance u/s 14A restricted to assessee's suo motu disallowance due to inapplicability of Rule 8D and availability of surplus interest-free funds. Transfer pricing adjustment on equity broking services (non-DVP/CH segment) remitted for recomputation considering 0.41% as arm's length price after allowing adjustment for sales and marketing function. Disallowance of interest expenses rejected due to availability of sufficient interest-free funds as per Supreme Court decision.
Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment for sales and marketing function. Port fee charges paid allowed at cost plus 25% markup as per agreement. No adjustment required for administrative support services provided to AE as margin exceeded arm's length price. Addition for brokerage on program trades disallowed as direct third-party transactions without benefitting AEs. Disallowance u/s 14A restricted to assessee's suo motu disallowance due to inapplicability of Rule 8D and availability of surplus interest-free funds. Transfer pricing adjustment on equity broking services (non-DVP/CH segment) remitted for recomputation considering 0.41% as arm's length price after allowing adjustment for sales and marketing function. Disallowance of interest expenses rejected due to availability of sufficient interest-free funds as per Supreme Court decision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
