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 rejected transfer pricing adjustments for technical know-how fees paid to associated enterprise. The tribunal found the technical services were inextricably linked to the assessee's business operations and essential for efficient business performance. The assessee demonstrated a higher net profit margin of 10.92% compared to comparable companies' 4.11%, which negated the need for additional markup. The tribunal directed the AO to grant TDS credit after document verification and compute interest under sections 234A and 234B considering CBDT's extended time limits. The decision follows the tribunal's previous ruling in the assessee's case for the 2018-19 assessment year, ultimately upholding the assessee's position on technical know-how expenses.
ITAT rejected transfer pricing adjustments for technical know-how fees paid to associated enterprise. The tribunal found the technical services were inextricably linked to the assessee's business operations and essential for efficient business performance. The assessee demonstrated a higher net profit margin of 10.92% compared to comparable companies' 4.11%, which negated the need for additional markup. The tribunal directed the AO to grant TDS credit after document verification and compute interest under sections 234A and 234B considering CBDT's extended time limits. The decision follows the tribunal's previous ruling in the assessee's case for the 2018-19 assessment year, ultimately upholding the assessee's position on technical know-how expenses.
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