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 disputes, rendering key holdings: The tribunal invalidated adjustments related to advertising and marketing (AMP) expenses, following precedential high court rulings that such expenditures do not constitute international transactions. Protective adjustments under Bright Line Test (BLT) and Transactional Net Margin Method (TNMM) were deleted. Compulsorily Convertible Debentures (CCDs) were affirmed as debt instruments, rejecting tax authority's recharacterization as equity. The tribunal also found improper transfer pricing methodology in interest receivables calculation, deleting upward adjustments. Regarding resale of designated services, the tribunal set aside Dispute Resolution Panel's (DRP) findings and directed reconsideration of comparable selection in accordance with legal principles.
ITAT adjudicated multiple transfer pricing disputes, rendering key holdings: The tribunal invalidated adjustments related to advertising and marketing (AMP) expenses, following precedential high court rulings that such expenditures do not constitute international transactions. Protective adjustments under Bright Line Test (BLT) and Transactional Net Margin Method (TNMM) were deleted. Compulsorily Convertible Debentures (CCDs) were affirmed as debt instruments, rejecting tax authority's recharacterization as equity. The tribunal also found improper transfer pricing methodology in interest receivables calculation, deleting upward adjustments. Regarding resale of designated services, the tribunal set aside Dispute Resolution Panel's (DRP) findings and directed reconsideration of comparable selection in accordance with legal principles.
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