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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT dismissed grounds 1 and 2 regarding validity of assessment order, relying on Aztec Software precedent. The Tribunal allowed ground 3 concerning Intra Group Services, following a coordinate Bench decision in assessee's own case for AY 2010-11, as Revenue failed to demonstrate distinguishing features in the current assessment year. Similarly, ground 4 regarding disallowance of mark-up charged by AEs on fixed asset purchases was allowed, directing deletion of the ALP adjustment. Regarding royalty payments, ITAT rejected Revenue's appeal, citing EKL Appliances which negated the need-benefit test, and Magneti Marelli Powertrain which established that TPO cannot segregate transactions already aggregated and benchmarked under TNMM to reduce their ALP to nil under CUP method.
ITAT dismissed grounds 1 and 2 regarding validity of assessment order, relying on Aztec Software precedent. The Tribunal allowed ground 3 concerning Intra Group Services, following a coordinate Bench decision in assessee's own case for AY 2010-11, as Revenue failed to demonstrate distinguishing features in the current assessment year. Similarly, ground 4 regarding disallowance of mark-up charged by AEs on fixed asset purchases was allowed, directing deletion of the ALP adjustment. Regarding royalty payments, ITAT rejected Revenue's appeal, citing EKL Appliances which negated the need-benefit test, and Magneti Marelli Powertrain which established that TPO cannot segregate transactions already aggregated and benchmarked under TNMM to reduce their ALP to nil under CUP method.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
