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 addressed transfer pricing adjustment concerning royalty payments for licensed manufacturing between appellant and non-UK entities. The tribunal determined that TPO's approach lacked objectivity in differentiating between UK and non-UK AEs, particularly given prior MAP proceedings accepting 4-5% compensation for AY 2013-14 and APA for AY 2018-19 to 2022-23. While MAP/APA decisions lack precedential value for different assessees, they carry significant persuasive weight for the same assessee. Applying consistency principles in tax matters, ITAT directed TPO to accept APA parameters for determining ALP of disputed transactions with non-UK AEs, effectively aligning treatment of royalty payments across jurisdictions.
ITAT addressed transfer pricing adjustment concerning royalty payments for licensed manufacturing between appellant and non-UK entities. The tribunal determined that TPO's approach lacked objectivity in differentiating between UK and non-UK AEs, particularly given prior MAP proceedings accepting 4-5% compensation for AY 2013-14 and APA for AY 2018-19 to 2022-23. While MAP/APA decisions lack precedential value for different assessees, they carry significant persuasive weight for the same assessee. Applying consistency principles in tax matters, ITAT directed TPO to accept APA parameters for determining ALP of disputed transactions with non-UK AEs, effectively aligning treatment of royalty payments across jurisdictions.
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