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 directed exclusion of several comparables for transfer pricing adjustments in software development services (Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, Bodhtree Consulting Ltd) and ITeS (Eclerx Services Ltd, Cosmic Global Ltd, Accentia Technologies Ltd, Infosys BPO Ltd) due to functional differences and lack of segmental information. The Tribunal allowed deductions under s.10A for UB Plaza Unit, Titanium STPI Unit, and the unit acquired from Reuters India, following previous favorable decisions. The issue of depreciation on goodwill was restored to AO for de novo adjudication. ITAT upheld DRP's direction to exclude communication and travel expenses from both export and total turnover while computing s.10A deduction, following HCL Technologies Ltd precedent, and affirmed deletion of software disallowance under s.40(a)(ia) per Tally Solutions ruling.
ITAT directed exclusion of several comparables for transfer pricing adjustments in software development services (Infosys Ltd, Persistent Systems Ltd, Tata Elexi Ltd, Bodhtree Consulting Ltd) and ITeS (Eclerx Services Ltd, Cosmic Global Ltd, Accentia Technologies Ltd, Infosys BPO Ltd) due to functional differences and lack of segmental information. The Tribunal allowed deductions under s.10A for UB Plaza Unit, Titanium STPI Unit, and the unit acquired from Reuters India, following previous favorable decisions. The issue of depreciation on goodwill was restored to AO for de novo adjudication. ITAT upheld DRP's direction to exclude communication and travel expenses from both export and total turnover while computing s.10A deduction, following HCL Technologies Ltd precedent, and affirmed deletion of software disallowance under s.40(a)(ia) per Tally Solutions ruling.
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