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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT remanded the transfer pricing (TP) adjustment matter relating to support services payment to AO for fresh consideration, finding that TPO erroneously rejected the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM). Regarding Section 10AA deduction for Special Economic Zone (SEZ) services, the Tribunal held that services provided to foreign customers involving warehousing, logistics, and handling qualify under SEZ Act definitions. The Tribunal directed the AO to delete disallowances, noting prior assessments had accepted the deduction's eligibility, and finding the services met statutory requirements for claiming deduction under Section 10AA of the Income Tax Act.
ITAT remanded the transfer pricing (TP) adjustment matter relating to support services payment to AO for fresh consideration, finding that TPO erroneously rejected the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM). Regarding Section 10AA deduction for Special Economic Zone (SEZ) services, the Tribunal held that services provided to foreign customers involving warehousing, logistics, and handling qualify under SEZ Act definitions. The Tribunal directed the AO to delete disallowances, noting prior assessments had accepted the deduction's eligibility, and finding the services met statutory requirements for claiming deduction under Section 10AA of the Income Tax Act.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
