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 for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.
Comparable selection for transfer pricing adjustment in the Information Process Management (IPM) segment was examined. UB Engineering Ltd. with negative operating margin of 46.58% was rejected as profitability is not a criteria, and future years' data was considered. Holtec Consulting Pvt. Ltd. and Neil Soft Ltd. were excluded as their functionality differed from the assessee, an Engineering, Procurement, and Construction (EPC) company. Info Edge India Ltd., an online search portal with substantially higher turnover, was rejected due to failing the Functional Asset Risk (FAR) test. The assessee's appeal was partly allowed, upholding certain comparables while rejecting others based on functional dissimilarities and FAR analysis.
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