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 Appellate Tribunal held that the term "One Time Upfront Amount" (referred to as premium, salami, cost, price, development charges, etc.) relates to a one-time payment made at the beginning of a lease, but it does not necessarily mean payment in one lump sum. The nature of such payments is that they are paid only once during the lease period, as opposed to recurring lease rent. The Revenue's contention that payment in installments cannot be considered a "One Time Payment" was incorrect. Consequently, the Revenue's appeal was dismissed.
The Appellate Tribunal held that the term "One Time Upfront Amount" (referred to as premium, salami, cost, price, development charges, etc.) relates to a one-time payment made at the beginning of a lease, but it does not necessarily mean payment in one lump sum. The nature of such payments is that they are paid only once during the lease period, as opposed to recurring lease rent. The Revenue's contention that payment in installments cannot be considered a "One Time Payment" was incorrect. Consequently, the Revenue's appeal was dismissed.
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