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 HC set aside the ITAT order concerning the TP adjustment and comparable selection, finding that ITAT failed to provide adequate reasons for including certain entities such as Comviva Technologies Ltd. and Cybercom Datamatics Information Solutions Ltd. The court noted that ITAT did not properly address the Assessee's contentions regarding the lack of functional comparability and absence of analysis by the TPO or DRP. Specifically, ITAT erred in accepting comparables without discussing the functional dissimilarities highlighted by the Assessee. Consequently, the HC remanded the matter to ITAT for reconsideration and directed it to pass a reasoned order on the Assessee's objections, ensuring proper evaluation of the comparability analysis in accordance with transfer pricing principles.
The HC set aside the ITAT order concerning the TP adjustment and comparable selection, finding that ITAT failed to provide adequate reasons for including certain entities such as Comviva Technologies Ltd. and Cybercom Datamatics Information Solutions Ltd. The court noted that ITAT did not properly address the Assessee's contentions regarding the lack of functional comparability and absence of analysis by the TPO or DRP. Specifically, ITAT erred in accepting comparables without discussing the functional dissimilarities highlighted by the Assessee. Consequently, the HC remanded the matter to ITAT for reconsideration and directed it to pass a reasoned order on the Assessee's objections, ensuring proper evaluation of the comparability analysis in accordance with transfer pricing principles.
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