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 ruled on multiple transfer pricing and tax issues for an Indian shipping company. The tribunal held that tonnage tax scheme provisions override standard transfer pricing methods for qualifying ships, rejecting TP adjustments on loan interest and ship-related transactions. Corporate guarantee commission was remanded to TPO/AO for arm's length price determination using prescribed methods. Regarding interest income from income tax refund, the tribunal classified it under 'Income from other sources' rather than business income, citing Section 244A. The decision followed precedent from earlier cases, providing relief to the assessee on transfer pricing adjustments related to qualifying ships and maintaining the standard treatment of tax refund interest.
ITAT ruled on multiple transfer pricing and tax issues for an Indian shipping company. The tribunal held that tonnage tax scheme provisions override standard transfer pricing methods for qualifying ships, rejecting TP adjustments on loan interest and ship-related transactions. Corporate guarantee commission was remanded to TPO/AO for arm's length price determination using prescribed methods. Regarding interest income from income tax refund, the tribunal classified it under 'Income from other sources' rather than business income, citing Section 244A. The decision followed precedent from earlier cases, providing relief to the assessee on transfer pricing adjustments related to qualifying ships and maintaining the standard treatment of tax refund interest.
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