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 in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).
The ITAT ruled in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).
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