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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HC upheld ITAT's decision deleting transfer pricing adjustments related to expatriate salary reimbursements and royalty payments. The court rejected TPO's contention that ALP should be nil due to assessee's losses, emphasizing that business losses do not negate the value of services or technical know-how. For expatriate costs, court noted these were pure reimbursements without markup and were subsumed in commission earnings already found arm's length under TNMM. Regarding royalty, HC affirmed that technical know-how procurement was a commercial decision outside TPO's review scope. Revenue's allegation of double deduction was dismissed for lack of substantiation. The court found no basis to interfere with ITAT's conclusions on both issues.
HC upheld ITAT's decision deleting transfer pricing adjustments related to expatriate salary reimbursements and royalty payments. The court rejected TPO's contention that ALP should be nil due to assessee's losses, emphasizing that business losses do not negate the value of services or technical know-how. For expatriate costs, court noted these were pure reimbursements without markup and were subsumed in commission earnings already found arm's length under TNMM. Regarding royalty, HC affirmed that technical know-how procurement was a commercial decision outside TPO's review scope. Revenue's allegation of double deduction was dismissed for lack of substantiation. The court found no basis to interfere with ITAT's conclusions on both issues.
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