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 held that reimbursements for SAP software installation, intranet, and maintenance charges are not taxable in India as 'Fees for Technical Services' under section 9(1)(vii) of the Income Tax Act. The tribunal directed the Assessing Officer to re-verify design and drawing details, placing the burden of proof on the assessee. Regarding interest chargeability for non-residents, the tribunal referenced precedent establishing that section 209(1) proviso has prospective effect only. Consequently, the tribunal deleted the disputed tax addition and accepted the assessee's grounds, maintaining judicial consistency with prior coordinate bench decisions from assessment year 1992-93 onwards.
ITAT held that reimbursements for SAP software installation, intranet, and maintenance charges are not taxable in India as 'Fees for Technical Services' under section 9(1)(vii) of the Income Tax Act. The tribunal directed the Assessing Officer to re-verify design and drawing details, placing the burden of proof on the assessee. Regarding interest chargeability for non-residents, the tribunal referenced precedent establishing that section 209(1) proviso has prospective effect only. Consequently, the tribunal deleted the disputed tax addition and accepted the assessee's grounds, maintaining judicial consistency with prior coordinate bench decisions from assessment year 1992-93 onwards.
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