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 multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents.
ITAT adjudicated multiple transfer pricing (TP) issues involving associated enterprises (AEs) transactions. The Tribunal comprehensively deleted TP adjustments related to external commercial borrowing (ECB) interest, royalty payments, and trade receivables/payables. Key holdings include: (1) ECB interest at LIBOR+500 basis is arm's length, (2) royalty payment determination at Nil is arbitrary, and (3) netting off notional interest considering both receivables and payables is appropriate. The Tribunal set aside CPC's mechanical adjustments, directing the Assessing Officer to verify suo-moto disallowances and employee contribution issues in accordance with established legal principles and recent judicial precedents.
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