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 deleted transfer-pricing adjustments in respect of AMP expenses and royalty payments and directed deletion of TP adjustments to service fees, applying the co-ordinate bench precedent and allowing the assessee's appeals on those issues. An ad hoc TP adjustment to global services was disallowed and the regional service fee challenge was allowed in favour of the assessee. The Tribunal remitted the Section 14A/read with Rule 8D disallowance to the AO for re-adjudication in light of the assessee's suo-moto salary disallowance. Allocation-related disallowances for Unit-I and Unit-II were deleted and relevant grounds allowed. Issues as to interest under s.234C and MAT credit were remitted to the AO for recomputation and adjudication.
The ITAT deleted transfer-pricing adjustments in respect of AMP expenses and royalty payments and directed deletion of TP adjustments to service fees, applying the co-ordinate bench precedent and allowing the assessee's appeals on those issues. An ad hoc TP adjustment to global services was disallowed and the regional service fee challenge was allowed in favour of the assessee. The Tribunal remitted the Section 14A/read with Rule 8D disallowance to the AO for re-adjudication in light of the assessee's suo-moto salary disallowance. Allocation-related disallowances for Unit-I and Unit-II were deleted and relevant grounds allowed. Issues as to interest under s.234C and MAT credit were remitted to the AO for recomputation and adjudication.
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