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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT addressed multiple issues regarding an IT company's tax assessment. The Tribunal left open the determination of whether the assessee operates as a KPO or software developer, citing insufficient reasoning from TPO/DRP. On corporate guarantee fees, ITAT directed benchmarking at 0.53% limited to actual guarantee periods. Regarding TDS under s.192, the matter of salary expense disallowance was remanded to AO for fresh verification of additional evidence submitted by assessee. The Tribunal set aside the 30% disallowance under s.40(a)(ia), directing AO to examine documentation supporting non-deduction of TDS where employee incomes fell below taxable threshold. Case remanded for limited review of salary payments and TDS compliance under s.192.
ITAT addressed multiple issues regarding an IT company's tax assessment. The Tribunal left open the determination of whether the assessee operates as a KPO or software developer, citing insufficient reasoning from TPO/DRP. On corporate guarantee fees, ITAT directed benchmarking at 0.53% limited to actual guarantee periods. Regarding TDS under s.192, the matter of salary expense disallowance was remanded to AO for fresh verification of additional evidence submitted by assessee. The Tribunal set aside the 30% disallowance under s.40(a)(ia), directing AO to examine documentation supporting non-deduction of TDS where employee incomes fell below taxable threshold. Case remanded for limited review of salary payments and TDS compliance under s.192.
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