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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ITAT remanded transfer pricing adjustments for reassessment regarding expense allocation and segmental reporting. Tribunal directed AO/TPO to verify assessee's allocation methodology consistent with AY 2021-22 practices and analyze internal CUP method for benchmarking book purchase transactions with AE. Examination to include comparison of AE discounts in controlled versus uncontrolled transactions. On trade payables enhancement issue, matter remitted to AO for verification of creditor confirmations and supporting documentation. Both grounds allowed for statistical purposes, with directive to provide assessee reasonable hearing opportunity during reassessment. AO to determine final position after examining additional evidence per legal requirements.
ITAT remanded transfer pricing adjustments for reassessment regarding expense allocation and segmental reporting. Tribunal directed AO/TPO to verify assessee's allocation methodology consistent with AY 2021-22 practices and analyze internal CUP method for benchmarking book purchase transactions with AE. Examination to include comparison of AE discounts in controlled versus uncontrolled transactions. On trade payables enhancement issue, matter remitted to AO for verification of creditor confirmations and supporting documentation. Both grounds allowed for statistical purposes, with directive to provide assessee reasonable hearing opportunity during reassessment. AO to determine final position after examining additional evidence per legal requirements.
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