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 transfer pricing comparables and foreign exchange gains, directing: (1) Net gain from foreign currency transactions of Rs. 17.02 crore to be treated as operating income; (2) Excluding four comparables (Manipal Digital Systems, CES, MPS, Domex E-Data) as functionally different; (3) Retaining Tech Mahindra Business Services as a valid comparable; (4) Excluding Integra Software Services, Vitae International Accounting, and Access Healthcare Services based on precedent; (5) Rejecting Global Healthcare Billing and Digicall Global as inappropriate comparables; (6) Including R Systems International as a comparable; and (7) Excluding Bhilwara Info Technology, Cosmic Global, and Jindal Intellicom from the comparable list for calculating Profit Level Indicator under Transactional Net Margin Method.
ITAT ruled on transfer pricing comparables and foreign exchange gains, directing: (1) Net gain from foreign currency transactions of Rs. 17.02 crore to be treated as operating income; (2) Excluding four comparables (Manipal Digital Systems, CES, MPS, Domex E-Data) as functionally different; (3) Retaining Tech Mahindra Business Services as a valid comparable; (4) Excluding Integra Software Services, Vitae International Accounting, and Access Healthcare Services based on precedent; (5) Rejecting Global Healthcare Billing and Digicall Global as inappropriate comparables; (6) Including R Systems International as a comparable; and (7) Excluding Bhilwara Info Technology, Cosmic Global, and Jindal Intellicom from the comparable list for calculating Profit Level Indicator under Transactional Net Margin Method.
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