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 HC affirmed the ITAT's decision that the APA concluded with the revenue was germane to the assessment year, given no change in functions performed, assets employed or risks assumed between the years covered by the APA and the year under scrutiny. The HC held that the TPO/CIT(A) must give effect to the APA's terms - including the agreed arm's-length margin - and reassess transactions accordingly. The Court rejected Revenue's contention that an APA is confined to the specific years agreed and cannot inform statutory transfer-pricing determination where FARs are unchanged, directing the assessing authorities to apply the APA's consolidated margin (19.26%) and FAR analysis in the assessment.
The HC affirmed the ITAT's decision that the APA concluded with the revenue was germane to the assessment year, given no change in functions performed, assets employed or risks assumed between the years covered by the APA and the year under scrutiny. The HC held that the TPO/CIT(A) must give effect to the APA's terms - including the agreed arm's-length margin - and reassess transactions accordingly. The Court rejected Revenue's contention that an APA is confined to the specific years agreed and cannot inform statutory transfer-pricing determination where FARs are unchanged, directing the assessing authorities to apply the APA's consolidated margin (19.26%) and FAR analysis in the assessment.
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