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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The ITAT ruled that receipts for services rendered under the Intra Group Service Agreement do not constitute Fees for Technical Services (FTS) under Article 13(4) of the India-UK DTAA, following previous tribunal decisions for AY 2018-19 and 2019-20. Similarly, advisory services provided to RCIPL-including identifying potential buyers, supporting presentation preparation, coordinating marketing, and advising on transaction options-did not satisfy the "make available" clause as they did not transfer technical knowledge, know-how, or skills. The Tribunal found that neither the Assessing Officer nor the DRP adequately reasoned how these services met the "make available" requirement. Consequently, both service fees were held not taxable in India.
The ITAT ruled that receipts for services rendered under the Intra Group Service Agreement do not constitute Fees for Technical Services (FTS) under Article 13(4) of the India-UK DTAA, following previous tribunal decisions for AY 2018-19 and 2019-20. Similarly, advisory services provided to RCIPL-including identifying potential buyers, supporting presentation preparation, coordinating marketing, and advising on transaction options-did not satisfy the "make available" clause as they did not transfer technical knowledge, know-how, or skills. The Tribunal found that neither the Assessing Officer nor the DRP adequately reasoned how these services met the "make available" requirement. Consequently, both service fees were held not taxable in India.
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