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 exclusion of Cybage Software P. Ltd. and Nihilent Ltd. from the final list of comparables due to lack of segmental revenue data and extraordinary acquisition events, respectively. Sagarsoft (India) Ltd.'s claim as a comparable was rejected based on absence of product development and insufficient evidence of on-site services. Conversely, R Systems Ltd. and Infomile Technologies Ltd. were directed to be included as comparables, the former despite differing financial year-ends and the latter due to functional similarity in software development services. Regarding adjustments for outstanding receivables, the AO/TPO was instructed to verify whether working capital adjustments already account for credit periods, and if so, no separate adjustment for interest on delayed receivables is warranted.
The ITAT upheld the exclusion of Cybage Software P. Ltd. and Nihilent Ltd. from the final list of comparables due to lack of segmental revenue data and extraordinary acquisition events, respectively. Sagarsoft (India) Ltd.'s claim as a comparable was rejected based on absence of product development and insufficient evidence of on-site services. Conversely, R Systems Ltd. and Infomile Technologies Ltd. were directed to be included as comparables, the former despite differing financial year-ends and the latter due to functional similarity in software development services. Regarding adjustments for outstanding receivables, the AO/TPO was instructed to verify whether working capital adjustments already account for credit periods, and if so, no separate adjustment for interest on delayed receivables is warranted.
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