Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
ITAT adjudicated multiple tax issues for the assessee, rendering key decisions: On bad debt deduction, ITAT held that claiming ascertained bad debt in the current assessment year is permissible, considering the tax rate remained consistent across fiscal years. The tribunal allowed the assessee's claim, finding no procedural bar in claiming the deduction. Regarding data field costs, ITAT determined these expenditures constitute direct business expenses correlated with market research fees. The tribunal accepted the assessee's submission, noting the expenditures were duly audited and represented legitimate operational costs. In transfer pricing matters, ITAT directed the AO/TPO to include a profitable comparable company in the economic analysis, rejecting persistent loss criteria. The tribunal also declined to treat provisions written back as operating income, emphasizing insufficient demonstration of direct business linkage.
ITAT adjudicated multiple tax issues for the assessee, rendering key decisions: On bad debt deduction, ITAT held that claiming ascertained bad debt in the current assessment year is permissible, considering the tax rate remained consistent across fiscal years. The tribunal allowed the assessee's claim, finding no procedural bar in claiming the deduction. Regarding data field costs, ITAT determined these expenditures constitute direct business expenses correlated with market research fees. The tribunal accepted the assessee's submission, noting the expenditures were duly audited and represented legitimate operational costs. In transfer pricing matters, ITAT directed the AO/TPO to include a profitable comparable company in the economic analysis, rejecting persistent loss criteria. The tribunal also declined to treat provisions written back as operating income, emphasizing insufficient demonstration of direct business linkage.
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