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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT set aside the AO's order and directed that the DRP revisit its directions regarding addition to returned income under the specified domestic transaction, in light of the amended statutory definition of "market value" and a controlling High Court decision on comparable uncontrolled price methodology. The Bench held that where an internal CUP exists it governs ALP; where no internal CUP exists, an external CUP based on distribution-company supply rates may be adopted. The AO/TPO may request the DRP to reconsider and, after examining the facts, issue modified directions for incorporation in the assessment order as warranted by law. The appeal is partly allowed for statistical purposes.
The ITAT set aside the AO's order and directed that the DRP revisit its directions regarding addition to returned income under the specified domestic transaction, in light of the amended statutory definition of "market value" and a controlling High Court decision on comparable uncontrolled price methodology. The Bench held that where an internal CUP exists it governs ALP; where no internal CUP exists, an external CUP based on distribution-company supply rates may be adopted. The AO/TPO may request the DRP to reconsider and, after examining the facts, issue modified directions for incorporation in the assessment order as warranted by law. The appeal is partly allowed for statistical purposes.
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