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 held that in transfer pricing comparability analysis, rigid application of an upper turnover filter is not mandatory and must be determined based on case-specific facts, including the turnover of the tested party. The tribunal emphasized that turnover filters aim to ensure comparability by selecting entities with broadly similar economic profiles, but fixed thresholds are inappropriate. The inclusion of a comparable lacking the requisite export turnover was directed to be reconsidered and excluded if it fails the 75% export turnover criterion. Regarding interest on overdue receivables from associated enterprises, the ITAT found that invoices due after the relevant financial year cannot attract interest adjustments for that year and ordered deletion of such adjustments. Consequently, the adjustments made on account of higher turnover comparables and interest on outstanding receivables were partially set aside and remanded for appropriate reconsideration in accordance with these findings.
The ITAT held that in transfer pricing comparability analysis, rigid application of an upper turnover filter is not mandatory and must be determined based on case-specific facts, including the turnover of the tested party. The tribunal emphasized that turnover filters aim to ensure comparability by selecting entities with broadly similar economic profiles, but fixed thresholds are inappropriate. The inclusion of a comparable lacking the requisite export turnover was directed to be reconsidered and excluded if it fails the 75% export turnover criterion. Regarding interest on overdue receivables from associated enterprises, the ITAT found that invoices due after the relevant financial year cannot attract interest adjustments for that year and ordered deletion of such adjustments. Consequently, the adjustments made on account of higher turnover comparables and interest on outstanding receivables were partially set aside and remanded for appropriate reconsideration in accordance with these findings.
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