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 deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed.
The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed.
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