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 allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin.
ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin.
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