Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT allowed assessee's appeal regarding transfer pricing adjustments on software development services and ECB interest payments. For SDS benchmarking, ITAT held TPO/DRP erred by including five high-turnover comparables (Infosys, Wipro, Larsen & Turbo Infotech, Mindtree, Tata Elxsi) without applying turnover filter. Matter remanded to TPO for fresh benchmarking using ten-times turnover filter range. Regarding INR-denominated ECB interest, ITAT ruled TPO incorrectly rejected assessee's SBI-PLR benchmarking approach in favor of Masala Bond rates. Following precedents including Adama India and Invesco India, ITAT held INR-denominated loans should be benchmarked against domestic Indian rupee lending rates, not external rates carrying different lender risks. Assessee's 10.45% interest rate against SBI-PLR 13.75% deemed arm's length. TP adjustment vacated. AO directed to verify advance tax credit claim per 26AS disclosure.
ITAT allowed assessee's appeal regarding transfer pricing adjustments on software development services and ECB interest payments. For SDS benchmarking, ITAT held TPO/DRP erred by including five high-turnover comparables (Infosys, Wipro, Larsen & Turbo Infotech, Mindtree, Tata Elxsi) without applying turnover filter. Matter remanded to TPO for fresh benchmarking using ten-times turnover filter range. Regarding INR-denominated ECB interest, ITAT ruled TPO incorrectly rejected assessee's SBI-PLR benchmarking approach in favor of Masala Bond rates. Following precedents including Adama India and Invesco India, ITAT held INR-denominated loans should be benchmarked against domestic Indian rupee lending rates, not external rates carrying different lender risks. Assessee's 10.45% interest rate against SBI-PLR 13.75% deemed arm's length. TP adjustment vacated. AO directed to verify advance tax credit claim per 26AS disclosure.
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