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 ruled in favor of the assessee on several transfer pricing issues. Firstly, it deleted the TP adjustment on royalty and service fee payments, following its earlier decisions in the assessee's own case. Secondly, it directed granting a working capital adjustment while computing the arm's length price, consistent with its prior ruling for the assessee. Thirdly, it excluded the comparable Axis Integrated Systems Limited from the final set, aligning with an earlier order. The Tribunal also upheld the assessee's revenue recognition policy for sales and marketing support services, relying on judicial precedents. Additionally, it instructed recomputing tax liability without levying interest u/ss 234A and 234C, as the assessee had paid advance tax within statutory timelines.
The Tribunal ruled in favor of the assessee on several transfer pricing issues. Firstly, it deleted the TP adjustment on royalty and service fee payments, following its earlier decisions in the assessee's own case. Secondly, it directed granting a working capital adjustment while computing the arm's length price, consistent with its prior ruling for the assessee. Thirdly, it excluded the comparable Axis Integrated Systems Limited from the final set, aligning with an earlier order. The Tribunal also upheld the assessee's revenue recognition policy for sales and marketing support services, relying on judicial precedents. Additionally, it instructed recomputing tax liability without levying interest u/ss 234A and 234C, as the assessee had paid advance tax within statutory timelines.
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