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 excluded four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech. Mahindra Ltd.) from the comparable array in transfer pricing adjustment. Two entities (Infosys BPO and Tech Mahindra) underwent extraordinary acquisitions within the prescribed two-year period under Rule 10B(4) and failed to meet the related party transaction filter of less than 25%. The tribunal rejected Revenue's argument regarding turnover filter, citing Bombay HC precedent in Pentair Water India Pvt. Ltd. case which had previously upheld exclusion based on turnover filter. ITAT directed TPO to recompute transfer pricing adjustment excluding all four entities, noting that assessee's IT-enabled services segment remained unchanged across assessment years 2010-11 to 2013-14.
ITAT excluded four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech. Mahindra Ltd.) from the comparable array in transfer pricing adjustment. Two entities (Infosys BPO and Tech Mahindra) underwent extraordinary acquisitions within the prescribed two-year period under Rule 10B(4) and failed to meet the related party transaction filter of less than 25%. The tribunal rejected Revenue's argument regarding turnover filter, citing Bombay HC precedent in Pentair Water India Pvt. Ltd. case which had previously upheld exclusion based on turnover filter. ITAT directed TPO to recompute transfer pricing adjustment excluding all four entities, noting that assessee's IT-enabled services segment remained unchanged across assessment years 2010-11 to 2013-14.
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