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 ruled against the assessee regarding applicability of section 92BA in a power supply transaction case. The Tribunal held that claiming deduction u/s 80IA is not prerequisite for invoking section 92BA provisions. The assessee's captive thermal plant transactions with related parties required arm's length price determination. The TPO correctly used internal comparables (power supply to 14 independent consumers) rather than state utility rates for benchmarking. The average rate of Rs. 2.97 per unit charged to other units, compared to assessee's transfer price of Rs. 7.85 per unit based on GSEB tariff, demonstrated significant price variation. The ITAT rejected assessee's argument that state electricity board rates should be the benchmark, affirming TPO's use of arithmetic mean from actual third-party transactions.
The ITAT ruled against the assessee regarding applicability of section 92BA in a power supply transaction case. The Tribunal held that claiming deduction u/s 80IA is not prerequisite for invoking section 92BA provisions. The assessee's captive thermal plant transactions with related parties required arm's length price determination. The TPO correctly used internal comparables (power supply to 14 independent consumers) rather than state utility rates for benchmarking. The average rate of Rs. 2.97 per unit charged to other units, compared to assessee's transfer price of Rs. 7.85 per unit based on GSEB tariff, demonstrated significant price variation. The ITAT rejected assessee's argument that state electricity board rates should be the benchmark, affirming TPO's use of arithmetic mean from actual third-party transactions.
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