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 affirmed that the lender and taxpayer qualify as associated enterprises under s.92A(2) (status assessed at any time during the previous year), dismissing the taxpayer's objection. The Tribunal directed benchmarking of interest on NCDs at 12.275% (including gross-up) and ordered exclusion of any portion of redemption premium already considered in prior years; adjustments to be given effect with regard to s.94B. Interest on foreign-currency CCDs was held at arm's length as paid below SBI PLR, so the AO/TPO's TP adjustment was deleted. Voluntarily disallowed CCD interest under s.40(a)(i) need not be bench-marked. No s.14A disallowance where no exempt income arose. Unabsorbed depreciation to be recomputed chronologically and demerger claims verified under s.72A. Notional interest addition deleted.
The ITAT affirmed that the lender and taxpayer qualify as associated enterprises under s.92A(2) (status assessed at any time during the previous year), dismissing the taxpayer's objection. The Tribunal directed benchmarking of interest on NCDs at 12.275% (including gross-up) and ordered exclusion of any portion of redemption premium already considered in prior years; adjustments to be given effect with regard to s.94B. Interest on foreign-currency CCDs was held at arm's length as paid below SBI PLR, so the AO/TPO's TP adjustment was deleted. Voluntarily disallowed CCD interest under s.40(a)(i) need not be bench-marked. No s.14A disallowance where no exempt income arose. Unabsorbed depreciation to be recomputed chronologically and demerger claims verified under s.72A. Notional interest addition deleted.
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