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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CBDT issued guidance on applying the Principal Purpose Test under India's DTAAs, effective from MLI's entry into force on October 1, 2019. The PPT provision enables denial of treaty benefits where obtaining such benefits was a principal purpose of any arrangement, unless aligned with the DTAA's object and purpose. The guidance clarifies prospective application timeframes - from the effective date for bilateral PPTs, and as per MLI Article 35 for MLI-modified treaties. Notably, existing grandfathering provisions in Cyprus, Mauritius and Singapore DTAAs remain outside PPT's scope. Tax authorities may reference BEPS Action 6 Report and UN Model Tax Convention Commentary for case-specific application, subject to India's reservations.
CBDT issued guidance on applying the Principal Purpose Test under India's DTAAs, effective from MLI's entry into force on October 1, 2019. The PPT provision enables denial of treaty benefits where obtaining such benefits was a principal purpose of any arrangement, unless aligned with the DTAA's object and purpose. The guidance clarifies prospective application timeframes - from the effective date for bilateral PPTs, and as per MLI Article 35 for MLI-modified treaties. Notably, existing grandfathering provisions in Cyprus, Mauritius and Singapore DTAAs remain outside PPT's scope. Tax authorities may reference BEPS Action 6 Report and UN Model Tax Convention Commentary for case-specific application, subject to India's reservations.
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