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 addressed transfer pricing adjustment concerning interest rate on loan extended by assessee to associated enterprise in Dubai at 1-year LIBOR plus 2.5% totaling 3.8% annually. Primary legal issue involved determining appropriate benchmark interest rate - whether Indian prevailing rates should apply given lender's Indian residence, or USD lending rates considering Dubai borrower's location. ITAT relied on Cotton Nature India precedent establishing that loan repayment currency determines applicable rate of return. Since record lacked clarity regarding agreed repayment currency, ITAT directed assessee to furnish supporting documentation establishing repayment currency terms. Based on such evidence, Assessing Officer and Transfer Pricing Officer must reconsider appropriate interest computation methodology for arms length pricing determination.
ITAT addressed transfer pricing adjustment concerning interest rate on loan extended by assessee to associated enterprise in Dubai at 1-year LIBOR plus 2.5% totaling 3.8% annually. Primary legal issue involved determining appropriate benchmark interest rate - whether Indian prevailing rates should apply given lender's Indian residence, or USD lending rates considering Dubai borrower's location. ITAT relied on Cotton Nature India precedent establishing that loan repayment currency determines applicable rate of return. Since record lacked clarity regarding agreed repayment currency, ITAT directed assessee to furnish supporting documentation establishing repayment currency terms. Based on such evidence, Assessing Officer and Transfer Pricing Officer must reconsider appropriate interest computation methodology for arms length pricing determination.
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