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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Tribunal held that Vishal Information Technologies Ltd. and Nucleus Net soft & GIS (India) Ltd. should be excluded from comparable selection for determining arm's length price of international transactions. Vishal Information Technologies Ltd. engaged in data conversion, digitization of documents, text conversion, and e-publishing, functionally different from assessee providing voice, communication, data entry, and financial management services. Nucleus Net soft & GIS Ltd. excluded due to different business model, export revenue filter, extraordinary events, and lack of segmental details. Company outsourced most business activities with major operating expenses for data processing charges, unlike assessee. Extraordinary event of amalgamation approved by Bombay High Court. Company had IT and ITeS segments considered as one without separate segmental details available. Therefore, these companies not comparable to assessee for transfer pricing adjustment.
Tribunal held that Vishal Information Technologies Ltd. and Nucleus Net soft & GIS (India) Ltd. should be excluded from comparable selection for determining arm's length price of international transactions. Vishal Information Technologies Ltd. engaged in data conversion, digitization of documents, text conversion, and e-publishing, functionally different from assessee providing voice, communication, data entry, and financial management services. Nucleus Net soft & GIS Ltd. excluded due to different business model, export revenue filter, extraordinary events, and lack of segmental details. Company outsourced most business activities with major operating expenses for data processing charges, unlike assessee. Extraordinary event of amalgamation approved by Bombay High Court. Company had IT and ITeS segments considered as one without separate segmental details available. Therefore, these companies not comparable to assessee for transfer pricing adjustment.
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