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 appellant relied on the Delhi High Court's judgment in Kusum Health Care Pvt. Ltd., which held that once working capital adjustment is granted, there is no need to impute interest on outstanding receivables at year-end as it gets subsumed in the working capital adjustment. The Tribunal agreed with this proposition but directed the TPO to examine the bills and ascertain whether interest should be imputed on bills realized after the credit period of 70 days. The High Court modified the order, directing the TPO to look into the entire aspect in light of the Kusum Health Care judgment and pass orders accordingly, without imputing interest on the bills.
The appellant relied on the Delhi High Court's judgment in Kusum Health Care Pvt. Ltd., which held that once working capital adjustment is granted, there is no need to impute interest on outstanding receivables at year-end as it gets subsumed in the working capital adjustment. The Tribunal agreed with this proposition but directed the TPO to examine the bills and ascertain whether interest should be imputed on bills realized after the credit period of 70 days. The High Court modified the order, directing the TPO to look into the entire aspect in light of the Kusum Health Care judgment and pass orders accordingly, without imputing interest on the bills.
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