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 deleted penalty under section 271(1)(c) imposed on transfer pricing adjustments involving manufacturing and trading segments. TPO made adjustments by using PBIT/Sales instead of assessee's PBDIT/Sales as Profit Level Indicator, modifying filters and comparables for benchmarking, and excluding certain operating items. Revenue authorities levied penalty solely because TPO's adjustments were upheld by CIT(A) and partly confirmed by ITAT. ITAT held that assessee furnished accurate details in return and transfer pricing study report using prescribed TNMM method under section 92C. Adjustments arose from interpretational differences on debatable issues, not inaccurate particulars. Neither TPO nor CIT(A) found arm's length price computed without good faith or due diligence. Explanation 7 to section 271(1)(c) governing transfer pricing penalties was neither invoked nor discussed. Penalty unsustainable as necessary conditions under Explanation 7 not satisfied. Appeal allowed.
ITAT deleted penalty under section 271(1)(c) imposed on transfer pricing adjustments involving manufacturing and trading segments. TPO made adjustments by using PBIT/Sales instead of assessee's PBDIT/Sales as Profit Level Indicator, modifying filters and comparables for benchmarking, and excluding certain operating items. Revenue authorities levied penalty solely because TPO's adjustments were upheld by CIT(A) and partly confirmed by ITAT. ITAT held that assessee furnished accurate details in return and transfer pricing study report using prescribed TNMM method under section 92C. Adjustments arose from interpretational differences on debatable issues, not inaccurate particulars. Neither TPO nor CIT(A) found arm's length price computed without good faith or due diligence. Explanation 7 to section 271(1)(c) governing transfer pricing penalties was neither invoked nor discussed. Penalty unsustainable as necessary conditions under Explanation 7 not satisfied. Appeal allowed.
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