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 partially allowed assessee's appeal regarding transfer pricing (TP) adjustment for corporate guarantee. The Tribunal held the corporate guarantee as an international transaction and directed the TPO/AO to compute the guarantee fee at 0.5% rate, deleting excess amount added. Regarding interest under section 244A, the Tribunal directed the assessee to approach the AO, who shall consider the interest claim in accordance with law, with the Principal Commissioner having final decision-making authority on interest period and calculation.
ITAT partially allowed assessee's appeal regarding transfer pricing (TP) adjustment for corporate guarantee. The Tribunal held the corporate guarantee as an international transaction and directed the TPO/AO to compute the guarantee fee at 0.5% rate, deleting excess amount added. Regarding interest under section 244A, the Tribunal directed the assessee to approach the AO, who shall consider the interest claim in accordance with law, with the Principal Commissioner having final decision-making authority on interest period and calculation.
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