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 allowed the assessee's appeal regarding section 80IA(10) deduction denial. The AO made a downward adjustment of Rs. 10.98 crore based on transfer pricing analysis of transactions between the eligible unit and its associated enterprise. However, ITAT held that existence of an "arrangement" between the deduction-seeking unit and AE is a mandatory precondition for invoking section 80IA(10) provisions. The AO failed to establish any such arrangement before referring the matter to TPO for arm's length price computation. Following precedents from Schmetz India and Mankind Pharma, ITAT ruled that without proving an arrangement, business transactions between eligible units and AEs do not constitute Specified Domestic Transactions under section 92BA, making transfer pricing analysis inapplicable and the adjustment unsustainable.
ITAT allowed the assessee's appeal regarding section 80IA(10) deduction denial. The AO made a downward adjustment of Rs. 10.98 crore based on transfer pricing analysis of transactions between the eligible unit and its associated enterprise. However, ITAT held that existence of an "arrangement" between the deduction-seeking unit and AE is a mandatory precondition for invoking section 80IA(10) provisions. The AO failed to establish any such arrangement before referring the matter to TPO for arm's length price computation. Following precedents from Schmetz India and Mankind Pharma, ITAT ruled that without proving an arrangement, business transactions between eligible units and AEs do not constitute Specified Domestic Transactions under section 92BA, making transfer pricing analysis inapplicable and the adjustment unsustainable.
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