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 made by excluding two comparable companies due to excessive related party transactions, rendering them un-comparable. Other comparables to be considered for arm's length price computation. AO's jurisdiction over expenditure for support services upheld as consistent with TPO's acceptance over the years. Cost allocation methodology change disallowed. Depreciation allowance for intangible assets like customer contracts and workforce granted at 25% rate based on ITAT decision in the assessee's favor. Additional ground raised allowed.
TP Adjustment made by excluding two comparable companies due to excessive related party transactions, rendering them un-comparable. Other comparables to be considered for arm's length price computation. AO's jurisdiction over expenditure for support services upheld as consistent with TPO's acceptance over the years. Cost allocation methodology change disallowed. Depreciation allowance for intangible assets like customer contracts and workforce granted at 25% rate based on ITAT decision in the assessee's favor. Additional ground raised allowed.
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