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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Global Account Management charges and Leaseline charges received by assessee were reviewed for tax classification. HC held that management charges qualify as Fees for Technical Services/Included Services (FTS/FIS) under Section 9(1)(vii), while Leaseline charges constitute Royalty under Section 9(1)(vi). Regarding Freight Logistic Support services, HC determined these do not qualify as FTS/FIS since customs clearance rules are publicly available information, not specialized knowledge. The court emphasized that FTS requires both specialized expertise and "make available" conditions where recipient gains independent capability. Creation of global workforce standards also did not meet FTS criteria. Software development aspects were addressed per Engineering Analysis Centre precedent. Appeal dismissed against revenue.
Global Account Management charges and Leaseline charges received by assessee were reviewed for tax classification. HC held that management charges qualify as Fees for Technical Services/Included Services (FTS/FIS) under Section 9(1)(vii), while Leaseline charges constitute Royalty under Section 9(1)(vi). Regarding Freight Logistic Support services, HC determined these do not qualify as FTS/FIS since customs clearance rules are publicly available information, not specialized knowledge. The court emphasized that FTS requires both specialized expertise and "make available" conditions where recipient gains independent capability. Creation of global workforce standards also did not meet FTS criteria. Software development aspects were addressed per Engineering Analysis Centre precedent. Appeal dismissed against revenue.
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