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 set aside CIT(A)'s order regarding TDS obligations under s.195 for license fees paid to non-resident associated enterprise. The appellate authority failed to address crucial aspects: taxability of license fees under India-USA DTAA Article 12, and applicability of s.195 TDS requirements. CIT(A)'s decision was influenced by assessee's subsequent year tax compliance but lacked proper reasoning under s.250(6). Following established principle that statutory procedures must be strictly followed, ITAT found CIT(A)'s adjudication procedurally deficient. Both Revenue's appeal and assessee's cross-objection allowed for statistical purposes, with matter remanded for fresh consideration.
ITAT set aside CIT(A)'s order regarding TDS obligations under s.195 for license fees paid to non-resident associated enterprise. The appellate authority failed to address crucial aspects: taxability of license fees under India-USA DTAA Article 12, and applicability of s.195 TDS requirements. CIT(A)'s decision was influenced by assessee's subsequent year tax compliance but lacked proper reasoning under s.250(6). Following established principle that statutory procedures must be strictly followed, ITAT found CIT(A)'s adjudication procedurally deficient. Both Revenue's appeal and assessee's cross-objection allowed for statistical purposes, with matter remanded for fresh consideration.
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