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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Comparable selection - Tribunal remanded issue of inclusion of companies to TPO to examine functional comparability after applying applicable filters. If functionally comparable, TPO directed to include for computing ALP. Turnover filter - Tribunal directed TPO to apply turnover filter of ten times and 1/10th on both sides, excluding companies outside this range. Infobeans exclusion - Tribunal upheld exclusion as not a KPO. Delay in receipts - Tribunal directed applying SBI rate of 6% with 60-day credit period for interest on delayed trade receivables, following earlier decisions. ALP - Arm's Length Price, TPO - Transfer Pricing Officer, TNMM - Transactional Net Margin Method, KPO - Knowledge Process Outsourcing, AE - Associated Enterprise.
Comparable selection - Tribunal remanded issue of inclusion of companies to TPO to examine functional comparability after applying applicable filters. If functionally comparable, TPO directed to include for computing ALP. Turnover filter - Tribunal directed TPO to apply turnover filter of ten times and 1/10th on both sides, excluding companies outside this range. Infobeans exclusion - Tribunal upheld exclusion as not a KPO. Delay in receipts - Tribunal directed applying SBI rate of 6% with 60-day credit period for interest on delayed trade receivables, following earlier decisions. ALP - Arm's Length Price, TPO - Transfer Pricing Officer, TNMM - Transactional Net Margin Method, KPO - Knowledge Process Outsourcing, AE - Associated Enterprise.
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