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 CIT(A)'s deletion of the transfer pricing upward adjustment by the AO, finding no infirmity in treating the deleted clause (i) of section 92BA as never having existed following its omission by the Finance Act, 2017, and thereby rejecting Revenue's grounds. The Tribunal agreed that the TPO's adoption of the internal CUP as MAM and the AO's reliance on the erstwhile provision did not sustain the addition. Further, ITAT deleted the penalty under section 271AA imposed for non-maintenance of records relating to specified domestic transactions. The appeals filed by the Revenue were dismissed, and the assessment adjustments and penalty were quashed.
ITAT upheld the CIT(A)'s deletion of the transfer pricing upward adjustment by the AO, finding no infirmity in treating the deleted clause (i) of section 92BA as never having existed following its omission by the Finance Act, 2017, and thereby rejecting Revenue's grounds. The Tribunal agreed that the TPO's adoption of the internal CUP as MAM and the AO's reliance on the erstwhile provision did not sustain the addition. Further, ITAT deleted the penalty under section 271AA imposed for non-maintenance of records relating to specified domestic transactions. The appeals filed by the Revenue were dismissed, and the assessment adjustments and penalty were quashed.
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