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 allowed the appeal in part and directed the TPO/AO to re-determine transfer pricing margins: export incentives (e.g., duty drawback, export incentives) and cash discount income are to be treated as operating revenue for the assessee and included in margin computations; miscellaneous expenses are operating in nature and must be included in operating expenses of comparables where applicable; for a specified comparable with audited segmental reporting, only the auto-component segment shall be used rather than entity-level results; three additional comparables identified by the assessee are to be included in the final comparable set. The ITAT remitted the matter for compliance consistent with these rulings.
The ITAT allowed the appeal in part and directed the TPO/AO to re-determine transfer pricing margins: export incentives (e.g., duty drawback, export incentives) and cash discount income are to be treated as operating revenue for the assessee and included in margin computations; miscellaneous expenses are operating in nature and must be included in operating expenses of comparables where applicable; for a specified comparable with audited segmental reporting, only the auto-component segment shall be used rather than entity-level results; three additional comparables identified by the assessee are to be included in the final comparable set. The ITAT remitted the matter for compliance consistent with these rulings.
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