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 assessee's income earned in the USA is taxable in India. The tie-breaker test under Article 4 of the India-US DTAA is not applicable, as the assessee's centre of vital interest remained in India. While the income is includable in the total income u/s 5 of the Income Tax Act, the Appellate Tribunal directed the Assessing Officer to grant credit for taxes paid abroad by the assessee on the same income to avoid double taxation.
The assessee's income earned in the USA is taxable in India. The tie-breaker test under Article 4 of the India-US DTAA is not applicable, as the assessee's centre of vital interest remained in India. While the income is includable in the total income u/s 5 of the Income Tax Act, the Appellate Tribunal directed the Assessing Officer to grant credit for taxes paid abroad by the assessee on the same income to avoid double taxation.
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