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 set aside the DRP's order regarding transfer pricing adjustments for royalty payments, directing the matter back to the TPO for further examination to establish the arm's length price using internal CUP as the most appropriate method. Alternatively, a mean arm's length royalty rate of 5.20% derived from external CUP agreements was deemed appropriate. The Tribunal relied on EKL Appliances Ltd. and Technimont ICB Pvt. Ltd. precedents, confirming that expenditure cannot be disallowed on grounds of necessity or prudence, and ALP determination requires comparison with uncontrolled transactions. The ITAT also deleted the TP adjustment related to AMP expenditure, recognizing the appellant as a full-fledged telecom service provider rather than a mere distributor, and noting the expenses were inextricably linked to business operations.
The ITAT set aside the DRP's order regarding transfer pricing adjustments for royalty payments, directing the matter back to the TPO for further examination to establish the arm's length price using internal CUP as the most appropriate method. Alternatively, a mean arm's length royalty rate of 5.20% derived from external CUP agreements was deemed appropriate. The Tribunal relied on EKL Appliances Ltd. and Technimont ICB Pvt. Ltd. precedents, confirming that expenditure cannot be disallowed on grounds of necessity or prudence, and ALP determination requires comparison with uncontrolled transactions. The ITAT also deleted the TP adjustment related to AMP expenditure, recognizing the appellant as a full-fledged telecom service provider rather than a mere distributor, and noting the expenses were inextricably linked to business operations.
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