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 allowed the assessee's appeal. Regarding the transfer pricing adjustment for interest charged on loans, the ITAT upheld the CIT(A)'s deletion of the adjustment, relying on the Cotton Natural (I) Pvt. Ltd. case, which applied the LIBOR rate for foreign currency denominated loans. The ITAT also upheld the CIT(A)'s deletion of the adjustment for commission on providing a corporate guarantee, following the Vaibhav Global Limited case and the Supreme Court's decision in S.A. Builders Ltd. The ITAT agreed with the assessee's contention on Section 14A disallowance, as sufficient own funds were available for investments, based on the Supreme Court's ruling in South Indian Bank Ltd. The ITAT upheld the deletion of the addition u/s 40(a) for delayed TDS deposit, relying on the Calcutta Export Company case.
The ITAT allowed the assessee's appeal. Regarding the transfer pricing adjustment for interest charged on loans, the ITAT upheld the CIT(A)'s deletion of the adjustment, relying on the Cotton Natural (I) Pvt. Ltd. case, which applied the LIBOR rate for foreign currency denominated loans. The ITAT also upheld the CIT(A)'s deletion of the adjustment for commission on providing a corporate guarantee, following the Vaibhav Global Limited case and the Supreme Court's decision in S.A. Builders Ltd. The ITAT agreed with the assessee's contention on Section 14A disallowance, as sufficient own funds were available for investments, based on the Supreme Court's ruling in South Indian Bank Ltd. The ITAT upheld the deletion of the addition u/s 40(a) for delayed TDS deposit, relying on the Calcutta Export Company case.
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