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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Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not subsumed under sales/services transaction. Such overdue receivables amount to providing funds to AE without charge, requiring separate benchmarking. TPO rightly benchmarked this transaction, but erred in applying SBI PLR of 13.27% instead of LIBOR rate for foreign currency receivables. ITAT directed TPO to apply LIBOR rate and determine appropriate mark-up over LIBOR based on risk factors involved in overdue receivables from AEs. Assessee's appeal allowed for statistical purposes.
Outstanding receivables from AEs exceeding agreed credit period constitutes separate international transaction of providing capital financing/lending receivables, not subsumed under sales/services transaction. Such overdue receivables amount to providing funds to AE without charge, requiring separate benchmarking. TPO rightly benchmarked this transaction, but erred in applying SBI PLR of 13.27% instead of LIBOR rate for foreign currency receivables. ITAT directed TPO to apply LIBOR rate and determine appropriate mark-up over LIBOR based on risk factors involved in overdue receivables from AEs. Assessee's appeal allowed for statistical purposes.
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