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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT adjudicated transfer pricing and corporate guarantee fee (CGF) disputes. For A.Y. 2015-16, the Tribunal remanded transfer pricing adjustments to the Assessing Officer (AO) for verification of internal and external Transactional Net Margin Method (TNMM) applied for export transactions with associated enterprises. Regarding CGF, the Tribunal allowed the claim at 0.19% for A.Y. 2015-16, consistent with judicial precedents. For A.Y. 2016-17, the Tribunal permitted CGF only up to 0.5%, disallowing the excess 0.12%. The revenue's grounds were partially allowed, with the matter being statistically remanded for further examination and providing the assessee an opportunity to present additional details.
ITAT adjudicated transfer pricing and corporate guarantee fee (CGF) disputes. For A.Y. 2015-16, the Tribunal remanded transfer pricing adjustments to the Assessing Officer (AO) for verification of internal and external Transactional Net Margin Method (TNMM) applied for export transactions with associated enterprises. Regarding CGF, the Tribunal allowed the claim at 0.19% for A.Y. 2015-16, consistent with judicial precedents. For A.Y. 2016-17, the Tribunal permitted CGF only up to 0.5%, disallowing the excess 0.12%. The revenue's grounds were partially allowed, with the matter being statistically remanded for further examination and providing the assessee an opportunity to present additional details.
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