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 M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. should be accepted as comparable entities for TP analysis under TNMM as they were initially selected and not persistent loss-making companies. M/s Spicer India Pvt. Ltd. was rightly included despite related party transactions as TNMM requires broad comparability. For M/s JBM Auto Ltd., the issue was restored to the AO/TPO to re-adjudicate after examining segmental information. Forex losses/gains were held operating in nature being linked to import transactions. Economic adjustments were denied as not granted earlier by the Tribunal. The forex loss disallowance u/s 43A was restored to the AO for fresh adjudication based on bifurcation of capital and revenue components. The additional depreciation claim was dismissed as not claimed originally and being revenue neutral.
The ITAT held that M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. should be accepted as comparable entities for TP analysis under TNMM as they were initially selected and not persistent loss-making companies. M/s Spicer India Pvt. Ltd. was rightly included despite related party transactions as TNMM requires broad comparability. For M/s JBM Auto Ltd., the issue was restored to the AO/TPO to re-adjudicate after examining segmental information. Forex losses/gains were held operating in nature being linked to import transactions. Economic adjustments were denied as not granted earlier by the Tribunal. The forex loss disallowance u/s 43A was restored to the AO for fresh adjudication based on bifurcation of capital and revenue components. The additional depreciation claim was dismissed as not claimed originally and being revenue neutral.
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