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 transfer pricing adjustment under Chapter X of the Income Tax Act, confirming that the foreign enterprise and its Indian PE constitute associated enterprises under Section 92A(2)(g). The PE was held to be a fixed place of business through which the HO's business is conducted, with no separation of capital or control. The Tribunal rejected the assessee's contention that the onshore agreement could be used as a comparable under the CUP method, finding it not at arm's length due to inadequate compensation. The presence of multiple persons and offices in India as PEs of the foreign enterprise was affirmed. The Tribunal upheld the TPO's determination of the ALP using the most appropriate method (TNMM), resulting in a transfer pricing adjustment of Rs. 22 Crores for offshore contract activities. The assessee's arguments challenging the PE status and adjustment were dismissed.
The ITAT upheld the transfer pricing adjustment under Chapter X of the Income Tax Act, confirming that the foreign enterprise and its Indian PE constitute associated enterprises under Section 92A(2)(g). The PE was held to be a fixed place of business through which the HO's business is conducted, with no separation of capital or control. The Tribunal rejected the assessee's contention that the onshore agreement could be used as a comparable under the CUP method, finding it not at arm's length due to inadequate compensation. The presence of multiple persons and offices in India as PEs of the foreign enterprise was affirmed. The Tribunal upheld the TPO's determination of the ALP using the most appropriate method (TNMM), resulting in a transfer pricing adjustment of Rs. 22 Crores for offshore contract activities. The assessee's arguments challenging the PE status and adjustment were dismissed.
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