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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The ITAT upheld the AO's transfer pricing adjustments except for the valuation of electricity and steam transfers between eligible and non-eligible units. The Tribunal ruled that electricity transfers should be valued at market rates charged by distribution companies, not at the TPO's adjusted rate, deleting the Rs. 32.68 crore adjustment. Similarly, steam transfers cannot be valued at nil cost as by-products; instead, cost of production valuation was accepted, deleting the Rs. 51.63 crore adjustment. The adhoc 10% disallowance on legal and consultancy fees was set aside and remanded for verification of TDS compliance per DRP directions. The issue of customs duty discrepancies was also remanded for fresh verification. Interest under sections 234B and 234C is mandatory but to be computed on the income determined post-order. Grounds relating to electricity and steam valuation were allowed; others were remanded or partly allowed.
The ITAT upheld the AO's transfer pricing adjustments except for the valuation of electricity and steam transfers between eligible and non-eligible units. The Tribunal ruled that electricity transfers should be valued at market rates charged by distribution companies, not at the TPO's adjusted rate, deleting the Rs. 32.68 crore adjustment. Similarly, steam transfers cannot be valued at nil cost as by-products; instead, cost of production valuation was accepted, deleting the Rs. 51.63 crore adjustment. The adhoc 10% disallowance on legal and consultancy fees was set aside and remanded for verification of TDS compliance per DRP directions. The issue of customs duty discrepancies was also remanded for fresh verification. Interest under sections 234B and 234C is mandatory but to be computed on the income determined post-order. Grounds relating to electricity and steam valuation were allowed; others were remanded or partly allowed.
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