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 Tribunal addressed various issues related to transfer pricing adjustments, including the selection of comparables, interest on trade receivables, and set-off of losses. Regarding comparables, the Tribunal upheld the inclusion of E-Infochips Bangalore Ltd. and Mindtree, rejecting the assessee's objections. However, it excluded Persistent Systems Ltd. due to the absence of inventory related to software products. Concerning interest on trade receivables, the Tribunal followed the DRP's decision to restrict interest to LIBOR plus 250 basis points, despite contrary Tribunal precedents, as the Revenue did not appeal the DRP's order. The Tribunal dismissed the assessee's ground regarding set-off of losses between units, citing the lack of objection before the DRP and the restriction u/s 92C(4) proviso. The order provides clarity on the Tribunal's approach to various transfer pricing issues.
The Tribunal addressed various issues related to transfer pricing adjustments, including the selection of comparables, interest on trade receivables, and set-off of losses. Regarding comparables, the Tribunal upheld the inclusion of E-Infochips Bangalore Ltd. and Mindtree, rejecting the assessee's objections. However, it excluded Persistent Systems Ltd. due to the absence of inventory related to software products. Concerning interest on trade receivables, the Tribunal followed the DRP's decision to restrict interest to LIBOR plus 250 basis points, despite contrary Tribunal precedents, as the Revenue did not appeal the DRP's order. The Tribunal dismissed the assessee's ground regarding set-off of losses between units, citing the lack of objection before the DRP and the restriction u/s 92C(4) proviso. The order provides clarity on the Tribunal's approach to various transfer pricing issues.
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