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 held that foreign exchange fluctuation, whether gain or loss, must be treated as operating in nature, rejecting the TPO's classification as non-operating based on Rule 10TA. The Tribunal noted that Rule 10TA pertains only to Safe Harbour Rules when specifically opted for by the assessee. Following precedents from Delhi HC (Ameriprise India) and Karnataka HC (Subex Ltd), the ITAT directed that forex fluctuations be treated as operating items. Similarly, reversal of provisions for leave encashment and gratuity were deemed operating items. Regarding interest on overdue receivables from AEs, the ITAT deleted the adjustment, noting the assessee's consistent practice of not charging interest from either AEs or non-AEs, with significantly longer delays (545 days) for non-AEs compared to AEs (185 days).
The ITAT held that foreign exchange fluctuation, whether gain or loss, must be treated as operating in nature, rejecting the TPO's classification as non-operating based on Rule 10TA. The Tribunal noted that Rule 10TA pertains only to Safe Harbour Rules when specifically opted for by the assessee. Following precedents from Delhi HC (Ameriprise India) and Karnataka HC (Subex Ltd), the ITAT directed that forex fluctuations be treated as operating items. Similarly, reversal of provisions for leave encashment and gratuity were deemed operating items. Regarding interest on overdue receivables from AEs, the ITAT deleted the adjustment, noting the assessee's consistent practice of not charging interest from either AEs or non-AEs, with significantly longer delays (545 days) for non-AEs compared to AEs (185 days).
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