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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The HC held that the impugned transfer pricing adjustment was applied to the petitioner's entire turnover/operating costs rather than being confined to international/related-party transactions, which is contrary to settled law. The petitioner may press all available submissions before the CIT(A) in the pending statutory appeal; the CIT(A) is directed to decide the appeal expeditiously, preferably within 12 months. Pending disposal of the appeal and for four weeks thereafter, the Revenue is restrained from recovering taxes and interest attributable to the excess transfer pricing adjustment (≈ Rs.11,55,90,71,049 or as correctly computed) and from taking further proceedings on that specific issue. Stay applications on other additions to be decided by the Principal Commissioner in accordance with law.
The HC held that the impugned transfer pricing adjustment was applied to the petitioner's entire turnover/operating costs rather than being confined to international/related-party transactions, which is contrary to settled law. The petitioner may press all available submissions before the CIT(A) in the pending statutory appeal; the CIT(A) is directed to decide the appeal expeditiously, preferably within 12 months. Pending disposal of the appeal and for four weeks thereafter, the Revenue is restrained from recovering taxes and interest attributable to the excess transfer pricing adjustment (≈ Rs.11,55,90,71,049 or as correctly computed) and from taking further proceedings on that specific issue. Stay applications on other additions to be decided by the Principal Commissioner in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
