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 directs selective inclusion and exclusion of comparables across multiple service segments. Key determinations include excluding Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd due to limited risk profile, remanding certain comparables for detailed verification, and accepting specific companies like Sonata Information Technology Ltd and Akshay Software Technologies Ltd. The tribunal mandated working capital adjustments and proportionate margin computations, emphasizing functional similarity and segmental compatibility as primary criteria for comparable selection. The ruling instructs the Assessing Officer to comprehensively re-evaluate comparable companies using precise filtering parameters across software development, IT-enabled services, and training segments.
ITAT directs selective inclusion and exclusion of comparables across multiple service segments. Key determinations include excluding Innovana Thinklabs Ltd. and K7 Computing Pvt Ltd due to limited risk profile, remanding certain comparables for detailed verification, and accepting specific companies like Sonata Information Technology Ltd and Akshay Software Technologies Ltd. The tribunal mandated working capital adjustments and proportionate margin computations, emphasizing functional similarity and segmental compatibility as primary criteria for comparable selection. The ruling instructs the Assessing Officer to comprehensively re-evaluate comparable companies using precise filtering parameters across software development, IT-enabled services, and training segments.
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