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 recalled its earlier order regarding the transfer pricing adjustment under section 92BA, acknowledging the omission of clause (i) by the Finance Act, 2017, which rendered the previous reliance on that clause invalid. However, the Tribunal recognized that the transaction involving the transfer of finished goods between non-eligible and eligible units falls within the scope of section 92BA(v). Consequently, the Tribunal allowed the revenue's miscellaneous application to recall its prior order and directed that the main appeal be listed for hearing on 30.09.2025. The decision clarifies that while section 92BA(i) is omitted, adjustments under other clauses of section 92BA remain valid, warranting a fresh consideration of the appeal.
The ITAT recalled its earlier order regarding the transfer pricing adjustment under section 92BA, acknowledging the omission of clause (i) by the Finance Act, 2017, which rendered the previous reliance on that clause invalid. However, the Tribunal recognized that the transaction involving the transfer of finished goods between non-eligible and eligible units falls within the scope of section 92BA(v). Consequently, the Tribunal allowed the revenue's miscellaneous application to recall its prior order and directed that the main appeal be listed for hearing on 30.09.2025. The decision clarifies that while section 92BA(i) is omitted, adjustments under other clauses of section 92BA remain valid, warranting a fresh consideration of the appeal.
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