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 ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee's ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.
ITAT ruled on several transfer pricing adjustments in the comparable selection process. The Tribunal excluded Cosmic Global for failing the 75% export sales filter and Eclerx Services due to functional dissimilarity. TCS e-Serve was directed to be included as functionally comparable. The Tribunal allowed foreign exchange gains to be treated as operating income, finding them directly related to the assessee's ITES services to AEs. The AO/TPO was directed to examine and consider correct working capital adjusted margins of Interglobe. ICRA Online was retained as a suitable comparable with 87% export earnings. Motif India Infotech was also directed to be included in the comparable set for TP analysis.
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