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 Income Tax Appellate Tribunal held that the receipt from supply planning services was not taxable as fees for technical services or royalty under the India-United Kingdom tax treaty. The coordinate bench had previously decided the identical issue, ruling that such receipts were not chargeable to tax. The Tribunal, following the coordinate bench's decision in the assessee's own case for the last 5 years, upheld the order of the Commissioner of Income Tax (Appeals) and dismissed the grounds of appeal raised by the Assessing Officer. The decision was rendered in favor of the assessee.
The Income Tax Appellate Tribunal held that the receipt from supply planning services was not taxable as fees for technical services or royalty under the India-United Kingdom tax treaty. The coordinate bench had previously decided the identical issue, ruling that such receipts were not chargeable to tax. The Tribunal, following the coordinate bench's decision in the assessee's own case for the last 5 years, upheld the order of the Commissioner of Income Tax (Appeals) and dismissed the grounds of appeal raised by the Assessing Officer. The decision was rendered in favor of the assessee.
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