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 the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
The ITAT held that the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
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