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 a transfer pricing dispute regarding the omission of section 92BA clause (i) by Finance Act, 2017, effective 01.04.2017. The tribunal determined that since the reference to Transfer Pricing Officer (TPO) was made post-04.2017, the omitted clause cannot be invoked. Consistent with prior ITAT bench rulings, the tribunal held that the deleted statutory provision should be considered as never having been part of the statute. Consequently, no transfer pricing adjustments can be made for domestic specified transactions. The decision was rendered in favor of the assessee, effectively invalidating the transfer pricing reference as legally unsustainable under the amended statutory framework.
ITAT adjudicated a transfer pricing dispute regarding the omission of section 92BA clause (i) by Finance Act, 2017, effective 01.04.2017. The tribunal determined that since the reference to Transfer Pricing Officer (TPO) was made post-04.2017, the omitted clause cannot be invoked. Consistent with prior ITAT bench rulings, the tribunal held that the deleted statutory provision should be considered as never having been part of the statute. Consequently, no transfer pricing adjustments can be made for domestic specified transactions. The decision was rendered in favor of the assessee, effectively invalidating the transfer pricing reference as legally unsustainable under the amended statutory framework.
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