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 multiple transfer pricing issues, primarily focusing on comparability and arm's length pricing. The tribunal upheld the deletion of AMP expenditure additions, finding no international transaction. The court rejected Syngene International Limited as a comparable due to unavailable segmental information. Sequent Research Limited was accepted as a valid comparable. Regarding interest on external commercial borrowings, the tribunal remanded the matter to obtain proper credit ratings, agreeing that LIBOR was an appropriate benchmarking method. The TP adjustment on raw material purchases was deleted after analyzing gross margins, with the assessee's margin of 54.59% deemed acceptable compared to the comparable companies' median of 35.28%. Most revenue grounds were dismissed, with appeals allowed for statistical purposes.
ITAT adjudicated multiple transfer pricing issues, primarily focusing on comparability and arm's length pricing. The tribunal upheld the deletion of AMP expenditure additions, finding no international transaction. The court rejected Syngene International Limited as a comparable due to unavailable segmental information. Sequent Research Limited was accepted as a valid comparable. Regarding interest on external commercial borrowings, the tribunal remanded the matter to obtain proper credit ratings, agreeing that LIBOR was an appropriate benchmarking method. The TP adjustment on raw material purchases was deleted after analyzing gross margins, with the assessee's margin of 54.59% deemed acceptable compared to the comparable companies' median of 35.28%. Most revenue grounds were dismissed, with appeals allowed for statistical purposes.
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