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 remanded the matter to the TPO for a fresh transfer pricing examination concerning the interest rate on ECB loans from the AE, directing the application of the FAR analysis in selecting comparables. The tribunal noted the absence of such analysis in prior proceedings and acknowledged the assessee's RBI approvals for payments to the AE. It emphasized that the TPO must consider RBI-prescribed interest rates relevant for benchmarking commercial borrowings during the relevant period. Consequently, the assessee's appeal was allowed for statistical purposes, mandating a reassessment consistent with these guidelines.
The ITAT remanded the matter to the TPO for a fresh transfer pricing examination concerning the interest rate on ECB loans from the AE, directing the application of the FAR analysis in selecting comparables. The tribunal noted the absence of such analysis in prior proceedings and acknowledged the assessee's RBI approvals for payments to the AE. It emphasized that the TPO must consider RBI-prescribed interest rates relevant for benchmarking commercial borrowings during the relevant period. Consequently, the assessee's appeal was allowed for statistical purposes, mandating a reassessment consistent with these guidelines.
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