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 adjudicated transfer pricing and tax assessment matters involving a software services company. The tribunal directed inclusion of Sasken Communication Technologies Ltd in comparable companies list, while excluding Wipro, Tata Elxsi, Infosys, and Larsen & Toubro Infotech due to segmental reporting disparities. On Rule 14A disallowance, the tribunal held that investments from non-interest bearing funds do not warrant interest expenditure disallowance. The tribunal restored the disallowance computation to the Assessing Officer, noting only dividend-yielding investments should be considered. Regarding section 143(1) adjustments, the tribunal advised the assessee to seek remedy through separate proceedings, finding the current forum inappropriate for addressing such grievances.
ITAT adjudicated transfer pricing and tax assessment matters involving a software services company. The tribunal directed inclusion of Sasken Communication Technologies Ltd in comparable companies list, while excluding Wipro, Tata Elxsi, Infosys, and Larsen & Toubro Infotech due to segmental reporting disparities. On Rule 14A disallowance, the tribunal held that investments from non-interest bearing funds do not warrant interest expenditure disallowance. The tribunal restored the disallowance computation to the Assessing Officer, noting only dividend-yielding investments should be considered. Regarding section 143(1) adjustments, the tribunal advised the assessee to seek remedy through separate proceedings, finding the current forum inappropriate for addressing such grievances.
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