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 addressed multiple transfer pricing issues regarding an assessee's international transactions. On the KPO versus software developer classification dispute, ITAT left the matter open for future determination due to insufficient reasoning from TPO/DRP. Regarding corporate guarantee fees, ITAT modified the TPO's assessment of 1.90% to 0.53%, aligning with the Hetero Labs Limited precedent. The tribunal directed computation based on actual guarantee periods rather than annualized basis. For letters of comfort, ITAT determined these were equivalent to corporate guarantees and required similar benchmarking at 0.53%, rejecting the TPO's higher rate of 1.90%. The decision established parity between ECB rates (1.67%) and corporate guarantee charges, mandating the latter be substantially lower.
The ITAT addressed multiple transfer pricing issues regarding an assessee's international transactions. On the KPO versus software developer classification dispute, ITAT left the matter open for future determination due to insufficient reasoning from TPO/DRP. Regarding corporate guarantee fees, ITAT modified the TPO's assessment of 1.90% to 0.53%, aligning with the Hetero Labs Limited precedent. The tribunal directed computation based on actual guarantee periods rather than annualized basis. For letters of comfort, ITAT determined these were equivalent to corporate guarantees and required similar benchmarking at 0.53%, rejecting the TPO's higher rate of 1.90%. The decision established parity between ECB rates (1.67%) and corporate guarantee charges, mandating the latter be substantially lower.
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