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 upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."
ITAT upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."
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