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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ITAT directed exclusion of two specified comparables from the TP benchmarking set for software development services, resulting in the taxpayer's margin of 11.88% falling within the ±3% range and negating the adjustment. The Tribunal deleted the TP adjustment for intra-group advertisement, marketing and promotion expenses, holding them not to be an international transaction. The Tribunal directed exclusion of a particular comparable in relation to contract R&D services. Disallowance of interest paid to an MSME and deemed income under s.41(1) was restored to the file of the AO for fresh adjudication after affording opportunity of hearing. Disallowance of finance-lease rentals was rejected consistent with prior bench rulings (owner: depreciation; user: rent). Issues under ss.234A/234B and short TDS/TCS credit were remitted to the AO for fresh decision.
ITAT directed exclusion of two specified comparables from the TP benchmarking set for software development services, resulting in the taxpayer's margin of 11.88% falling within the ±3% range and negating the adjustment. The Tribunal deleted the TP adjustment for intra-group advertisement, marketing and promotion expenses, holding them not to be an international transaction. The Tribunal directed exclusion of a particular comparable in relation to contract R&D services. Disallowance of interest paid to an MSME and deemed income under s.41(1) was restored to the file of the AO for fresh adjudication after affording opportunity of hearing. Disallowance of finance-lease rentals was rejected consistent with prior bench rulings (owner: depreciation; user: rent). Issues under ss.234A/234B and short TDS/TCS credit were remitted to the AO for fresh decision.
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