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 ITAT held that the Transfer Pricing Officer (TPO) should consider comparables dealing in electronic products only, supported by a technical expert's certificate, while determining the arm's length price for the assessee, a 100% Export Oriented Unit (EOU). The Tribunal directed the TPO to apply filters of export turnover exceeding 75% of total turnover and related party transactions less than 25%. The assessee was also allowed to bring fresh comparables justifying its arm's length price determination, keeping in mind the prescribed filters. The issue of capacity utilization claim denial was remanded to the TPO for consideration while determining the arm's length price. Regarding the disallowance u/s 40A(a) for cash payments exceeding Rs. 20,000/-, the Assessing Officer was directed to examine the issue after providing adequate opportunity to the assessee. The appeals were allowed for statistical purposes with the above directions.
The ITAT held that the Transfer Pricing Officer (TPO) should consider comparables dealing in electronic products only, supported by a technical expert's certificate, while determining the arm's length price for the assessee, a 100% Export Oriented Unit (EOU). The Tribunal directed the TPO to apply filters of export turnover exceeding 75% of total turnover and related party transactions less than 25%. The assessee was also allowed to bring fresh comparables justifying its arm's length price determination, keeping in mind the prescribed filters. The issue of capacity utilization claim denial was remanded to the TPO for consideration while determining the arm's length price. Regarding the disallowance u/s 40A(a) for cash payments exceeding Rs. 20,000/-, the Assessing Officer was directed to examine the issue after providing adequate opportunity to the assessee. The appeals were allowed for statistical purposes with the above directions.
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