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 determined that for benchmarking outstanding receivables from Associated Enterprises (AEs), the applicable interest rate should be LIBOR, not domestic prime lending rates. The tribunal found the average LIBOR rate for 1-4-2005 to 31-3-2006 was 4.42%, and since the assessee charged 6% interest, which exceeded LIBOR, no additional transfer pricing adjustment was warranted. The decision emphasized that international transactions with AEs must be evaluated using international benchmark rates like LIBOR or EURIBOR, rather than domestic lending rates, ensuring arm's length pricing principles are consistently applied in cross-border financial transactions.
ITAT determined that for benchmarking outstanding receivables from Associated Enterprises (AEs), the applicable interest rate should be LIBOR, not domestic prime lending rates. The tribunal found the average LIBOR rate for 1-4-2005 to 31-3-2006 was 4.42%, and since the assessee charged 6% interest, which exceeded LIBOR, no additional transfer pricing adjustment was warranted. The decision emphasized that international transactions with AEs must be evaluated using international benchmark rates like LIBOR or EURIBOR, rather than domestic lending rates, ensuring arm's length pricing principles are consistently applied in cross-border financial transactions.
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